NHTSA Complaint #10986110 — 2016 DODGE GRAND CARAVAN

THE 2016 DODGE GRAND CARAVAN WAS THE DIRECT CAUSE OF INJURY DURING APPROPRIATE AND EXPECTED USE OF THE VEHICLE. THE VEHICLE DID NOT MALFUNCTION. I WAS SITTING IN THE MIDDLE LEFT PASSENGER'S SEAT WHILE THE VEHICLE WAS IN PARK. I WAS NOT WEARING A SEATBELT BECAUSE THE VEHICLE WAS OFF AND IN A SAFE PARKING LOT. I ATTEMPTED TO ENGAGE THE RECLINING FUNCTION OF THE SEAT. THE SEAT FLEW FORWARD WITH EXTRAORDINARY FORCE UPON ENGAGING THE RECLINER LEVER. THE SEATS HAVE STOW-N-GO, A MECHANICAL FEATURE THAT FOLDS THE SEAT INTO THE FLOOR FOR STORAGE. THE LEVER TO ENGAGE STOW-N-GO AND THE LEVER TO ENGAGE RECLINE ARE THE SAME LEVER, AND THERE IS NO WARNING SIGN ON THE SEAT, IN THE VEHICLE, OR IN THE OWNER'S MANUAL. THE HEADREST FOLDED FORWARD, STRIKING ME IN THE BACK OF THE HEAD AND NECK, AND THE SEAT STRUCK MY BACK. I RECEIVED A CONCUSSION, WHIPLASH, AND PERMANENT HEARING DAMAGE AND TINNITUS DUE TO THE IMPACT. MEDICAL TREATMENT IS ONGOING TO DETERMINE SEVERITY OF COMPRESSED NERVES AND DAMAGE TO BONE, WITH SYMPTOMS PERSISTING FIVE MONTHS AFTER AND ARE CONSIDERED TO CONTINUE PERSISTING FOR MONTHS BY MEDICAL PROFESSIONALS BECAUSE OF THE TRAUMA DIRECTLY CAUSED BY THE VEHICLE.