U.S. Court of Appeals for the Third Circuit
Millentine Coates v. Ford Motor Co
August 31, 2026
Summary
The Third Circuit affirmed summary judgment for Ford on Coates’s products-liability claim. It predicted that Virgin Islands law would adopt the malfunction theory under Section 3, but held that the theory is unavailable when the allegedly defective product remains available for inspection and the plaintiff has not exhausted reasonable inspection opportunities. The court further held that, even if Section 3 applied, Coates’s evidence did not permit a reasonable factfinder to infer that a defect existed when the vehicle left Ford’s control rather than arising from later use, repairs, or modifications.