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Abstract

A single line of code can now cause a car crash, deny a loan, or—as in the case of Ameer v. Lyft—contribute to a man’s death. Traditional product liability law, born in the era of smokestacks and assembly lines, still assumes that only tangible things can be defective products. When software replaces machinery and algorithms make life-or-death decisions, courts face a question: can code itself be a defective product? The answer matters enormously. If courts decline to treat mass-marketed applications as “products,” victims of dangerous software may be left without recourse. On the other hand, if they expand liability too far, technological innovation could stall under the weight of litigation. In Ameer v. Lyft, Inc., the Missouri Court of Appeals for the Eastern District addressed a question in product liability law which has yet to be addressed by the United States Supreme Court: whether a mobile ridesharing application, like Lyft, qualifies as a “product” subject to product liability claims. The Court of Appeals held that a mobile rideshare application can qualify as a “product” under Missouri products liability law when the alleged injury stems from a defective design and it is sufficiently analogous to tangible goods in its commercial distribution.

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