Robertson v. Toyota Motor Corporation, Nos. A26A0988, A26A0989, 2026 WL 2580937, __ S.E.2d __ (Ga. Ct. App. Sept. 1, 2026). The court (Hodges, J.; Barnes, P.J., and Markle, J., concur) affirms the estate’s appeal and affirms in part and reverses in part Toyota’s cross-appeal after a carbon-monoxide death involving a vehicle left running in an attached garage. Summary judgment for the out-of-possession landlord was proper because the estate alleged failure to install a detector, rather than defective construction or disrepair. Id. at *1–4. The court upheld exclusion of the design expert for insufficient case-specific facts and reliable methodology, but upheld admission of the warnings expert under the flexible Daubert inquiry. Id. at *5–9. Toyota was entitled to partial summary judgment on punitive damages: the estate had withdrawn its pain-and-suffering claim, and wrongful death and related funeral and ante mortem expenses did not support such damages. Id. at *9–10.
