The “safer production of goods is an ‘underlying principle’ of products liability law.” Smith v. Eli Lilly & Co., 137 Ill.2d 222, (1990). Indeed, Illinois courts have long recognized a distinction between a motor vehicle crash occurring and a person’s injuries being enhanced by a defective vehicle. “[A]n auto manufacturer must foresee that its cars will sometimes be involved in accidents—and . . . provide consumers with reasonable protections under the circumstances surrounding particular accidents.” Malen v. MTD Products, Inc., 628 F.3d 296, 311 (7th Cir. 2010) (applying Illinois law); citing Buehler v. Whalen, 70 Ill.2d 51 (1977); Mack v. Ford Motor Co., 283 Ill.App.3d 52 (1996); Oakes v. General Motor Corp., 257 Ill.App.3d 10 (1994); Bean v. Volkswagenwerk Aktiengesellschaft of Wolfsburg, Germany, 109 Ill.App.3d 333(1982).The premise underlying the crashworthiness doctrine is that some products, although not made for certain purposes—such as accidents—should nevertheless be reasonably designed to minimize the injury-producing effect of an accident. A defect is not merely the conclusion that the product failed and caused injury, but that the product failed to provide the consumer with reasonable protection under the circumstances surrounding a particular accident. The crashworthiness doctrine is consistent with the idea that although a defendant’s conduct is not a proximate cause if some intervening act supersedes the defendant’s negligence, a reasonably foreseeable intervening act, such as an accident, does not relieve the defendant of liability.
Id. (citations omitted).