Apple Inc. isn’t liable for a distracted-driving accident that left two people dead and rendered a child a paraplegic, the U.S. Court of Appeals for the Fifth Circuit held Dec. 18.

The decision is the first by a federal appeals court to address the phone maker’s liability in a crash caused by a driver’s smartphone use. Here, the Fifth Circuit held Apple can’t be held liable for failing to put a “lock-out” feature on earlier versions of its iPhones. Such a feature prevents customers from texting while driving.

The ruling is consistent with a number of state and lower...