Tesla Autopilot Suit Over Fatal Florida Crash Goes to Trial (1)

Tesla Inc. must go to trial on claims that the company has some liability for a 2019 fatal crash in Florida that occurred while its autopilot system was engaged but failed to detect a parked SUV in the vehicle’s path.

Although the warnings about Tesla’s autopilot system in the owner’s manual appear to be unambiguous, the plaintiff’s failure to warn claim in part rests on a theory that the warnings were “inadequate due to their inaccessibility,” Judge Beth Bloom of the US District Court for the Southern District of Florida said Thursday, partially denying Tesla summary judgment.

The court granted Tesla summary judgment on the plaintiff’s defective manufacturing and negligent misrepresentation claims, but denied judgment as to the strict products liability and failure to warn claims.

Neima Benavides brought the suit after a Model S Tesla collided with another car in an intersection. The driver had engaged the car’s autopilot features, which included the traffic aware cruise control that limits the vehicle’s speed to 45 miles per hour. The driver then manually accelerated the car, while leaving autopilot features on.

The defective manufacturing claim failed because the plaintiffs didn’t show that the autopilot system in the car deviated from the intended design, Bloom said.

The negligent misrepresentation claim also failed because it wasn’t clear that Tesla owed drivers a duty that would give rise to such a claim.

But failure-to-warn claims survived because the dangers of relying on driver assistance technology isn’t an obvious danger that everyone agrees on, Bloom said.

“The term ‘Autopilot’ itself is a potentially confusing term as it arguably implies to the user that the 2019 Model S was more autonomous or at least had more capabilities than it really did,” the judge said. Given Tesla’s statements about the capabilities of the autopilot system, there was a dispute about whether it would be obvious to average consumers to not trust the system to avoid collisions, Bloom added.

Bloom also noted that the warnings on the vehicles are “more akin to instructions than warnings,” she said. And instructions don’t satisfy a manufacturer’s duty to warn, Bloom said.

Bloom allowed a design defect claim to proceed because the plaintiffs showed that the system’s design led drivers to “become complacent and over rely on Autopilot to operate their vehicles.”

The plaintiffs are represented by Singleton Schreiber LLP, Poses & Poses PA, and Eaton & Wolk PL. Tesla is represented by Bowman and Brooke LLP.

The case is Benavides v. Tesla Inc., S.D. Fla., No. 1:21-cv-21940, 6/26/25.