On August 1, 2025, a Miami jury rendered a verdict that immediately reverberated through the products liability community. In Benavides v. Tesla, jurors awarded more than $240 million in damages, including $200 million in punitive damages, after finding Tesla partially responsible for a fatal 2019 motor vehicle accident involving its Autopilot system. The verdict was the first in the United States to hold Tesla liable in a wrongful death action tied directly to Tesla's Autopilot's operation, and it arrived after years of litigation and intense public scrutiny over advanced driver-assist systems. Tesla has vowed to appeal, and post-trial motions will almost certainly test the size and constitutionality of the punitive damages award.
Benavides is significant, not only for its outcome, but for the reasoning that carried the case to trial. The court's rulings on summary judgment, admissibility, and punitive damages relied heavily on Florida product liability precedent and on federal evidentiary standards. Understanding the decision through that legal lens is critical for companies developing and defending automated technologies, as it illustrates both the opportunities for narrowing claims and the risks of punitive exposure when marketing statements are viewed as overpromising.
Factual Background
The events that gave rise to the case unfolded in April 2019 in Key Largo. George McGee was driving a Tesla Model S equipped with Autopilot when the vehicle failed to stop at a T-intersection, striking a parked car. The collision killed a pedestrian, Naibel Benavides Leon, and seriously injured Dillon Angulo. McGee admitted he had been distracted by his phone. Plaintiffs did not dispute his inattentiveness but argued that Tesla bore independent responsibility because the Autopilot system could be engaged on a road outside its intended operational design domain. It was further argued Tesla's driver-monitoring measures, which were based primarily on steering torque, were insufficient to ensure the driver remained attentive.
The Plaintiffs also contended Tesla's marketing of Autopilot had fostered a false impression of safety and autonomy, which encouraged drivers to rely on the system in conditions it was not designed to handle. After two weeks of trial, the jury concluded Tesla shared fault for the crash and imposed an extraordinary punitive award.
Issue at Hand
The trial turned on two interrelated questions. First, whether Tesla's Autopilot system was defectively designed under Florida law, because it could be activated in unsafe conditions and failed to adequately monitor driver attention. Second, whether Tesla's public statements and marketing materials created a basis for punitive damages by suggesting capabilities beyond what the system could safely deliver. For the defense, the challenge was to focus jurors on the driver's admitted distraction and to demonstrate the crash was caused by misuse, not any inherent defect in the vehicle's design.
Negligent Misrepresentation and Manufacturing Defect Claims
Before trial, Tesla moved for summary judgment on all claims. The court granted the motion in part, dismissing the manufacturing defect and negligent misrepresentation causes of action. Regarding the negligent misrepresentation cause of action, the court applied Florida precedent requiring that such a claim rest on a duty of care between the parties. Citing Gilchrist Timber Co. v. ITT Rayonier, Inc., 696 So.2d 334 (Fla. 1997), the court emphasized Tesla owed no direct duty to the plaintiffs sufficient to support reliance-based liability. This ruling was an early defense win that narrowed the case to design defect and failure-to-warn theories.
On the manufacturing claim, the court relied on Florida's settled distinction between design defects [one where the entire product line is alleged to be flawed and the other concerning isolated manufacturing flaws]. The plaintiffs failed to offer evidence of a departure from Tesla's intended design, and the court accordingly dismissed that cause of action.
Florida Product Liability Standards
For the claims that survived, the court turned to Florida's design-defect standards. Since Aubin v. Union Carbide Corp., 177 So.3d 489 (Fla. 2015), Florida has permitted plaintiffs to prove defectiveness under one of two tests:
- The consumer-expectations test, which considers whether the product performed as safely as an ordinary consumer would expect, or
- The risk-utility test, which balances the product's risks against its benefits.
In Benavides, the court concluded the Plaintiffs raised triable issues under both standards. More specifically, the court concluded a reasonable jury could find that a system permitting activation in conditions it was not designed for failed ordinary consumer expectations and that feasible alternatives, such as stricter operational design domain gating, might have reduced foreseeable misuse.
Evidentiary Rulings and their Incidents
The evidentiary battles were equally consequential. The plaintiffs sought to introduce a broad array of other Tesla accidents to show notice and pattern. The court applied Federal Rule of Evidence 403 and Eleventh Circuit precedent such as United States v. Gonzalez, 724 F.3d 1256 (10th Cir. 2013), stressing that motions in limine should be granted only where the evidence is clearly inadmissible. Ultimately, the court excluded a large catalogue of "other incidents" as unduly prejudicial and permitted only a narrow set of comparable crashes with substantial similarity of the facts at issue. This ruling gave Tesla an important buffer against the cumulative impact of anecdotal evidence that tends to overwhelm the jury.
The court also enforced the Daubert standard rigorously, ruling experts were confined to opinions disclosed in their reports and methodologies vetted for reliability. This limited the Plaintiffs' ability to expand their expert case mid-trial and underscores the continuing importance of careful Daubert practice in complex product liability cases. Rink v. Cheminova, Inc., 400 F.3d 1286 (11th Cir. 2005).
Punitive Damages
Perhaps the most consequential ruling concerned punitive damages. Florida Statutes §768.72 requires plaintiffs to make a prima facie showing of intentional misconduct or gross negligence before a punitive claim may be presented to a jury. Florida courts have long described this threshold as akin to criminal recklessness, drawing from the Florida Supreme Court's decision in Carraway v. Revell, 116 So.2d 16 (1959) and reaffirmed in Valldares v. Bank of America, 197 So.3d 1 (Fla. 2016). Tesla argued that the Plaintiffs had not met this stringent standard. The court disagreed, finding that evidence regarding Tesla's marketing of Autopilot -- when combined with testimony about design choices and warnings -- could permit a jury to conclude the company consciously disregarded known safety risks.
By allowing the claim for punitive damages to reach the jury, the court opened the door to evidence about Tesla's statements and promotional materials, which the Plaintiffs capitalized on in closing argument. The $200 million punitive award demonstrates the power of marketing evidence to inflame juror perceptions of alleged corporate indifference, even where a driver's own negligence is an undisputed cause of the crash.
Conclusion
The Benavides verdict stands as a cautionary tale for defendants confronting product liability claims in the era of automated driving. Although Tesla secured meaningful pretrial victories, including the dismissal of several claims and the exclusion of sweeping "other incident"-type evidence, the Plaintiffs were able to focus the case on design decisions and marketing messages. The combination proved potent, resulting in one of the largest products liability verdicts ever rendered against an automaker in Florida.
The case underscores several lessons. Design-defect theories grounded in operational design domain and driver monitoring are here to stay, and they will often be framed as foreseeable misuse rather than pure operator error. Marketing materials and public statements must be treated as potential trial exhibits with punitive implications, not simply as sales tools. And while motions in limine and Daubert challenges remain essential; they may not be enough if jurors perceive a gap between how a product is presented and how it performs in practice.
On appeal, Tesla is likely to challenge both the sufficiency of the evidence and the constitutional excessiveness of the punitive award. Regardless of the outcome, Benavides v. Tesla will influence how courts and juries evaluate advanced driver-assist technology for years to come. From the defense perspective, the case reminds us that future litigation in this space will turn less on whether a driver made a mistake and more on whether the manufacturer did enough to anticipate that mistake through design monitoring and marketing practices.
