How have courts interpreted the provisions of Proposition 213 of the California Civil Code 3333.4 of the Vehicle Accident Prevention Act to limit damages in a product liability claim?

Hodges concluded that Proposition 213 "was primarily intended to limit awards against insured drivers." (Hodges v. Superior Court, supra, 21 Cal.4th at p. 116, 86 Cal.Rptr.2d 884, 980 P.2d 433.) Thus, the ballot arguments, "considered as a whole, ... indicate that voters were being urged to distinguish between law-abiding motorists who pay for liability insurance, on the one hand, and law-breaking uninsured motorists who refuse to pay for such insurance on the other. By limiting the amount of damages available to uninsured motorists, the law-abiding motorists would receive some savings in the form of reduced premiums. The arguments for and against the measure refer principally to remedying an imbalance in the justice system that resulted in unfairness when an accident occurred between two motorists one insured and the other not." (Ibid.) The stated purposes of the statute of "punishing illegal behavior and encouraging personal responsibility are emphatically directed at `reform[ing] an unfair system' with respect to law-abiding drivers who 'pick up the tab'i.e., those who `play by the rules' and `take personal responsibility' [citation] but have been required to `pay additional premiums to protect themselves from uninsured drivers.'" (Id, at p. 117, 86 Cal.Rptr.2d 884, 980 P.2d 433.)

We thus determined in Hodges that Civil Code section 3333.4 was intended to resolve inequities involving the allocation of costs between motorists who carry automobile liability insurance and motorists who do not. The formerscofflaw uninsured motoristsare held accountable as both a punishment and incentive; the lattermotorists who obey the financial responsibility lawsare the beneficiaries. We found nothing in the ballot materials suggesting "that such punishment or incentive was also intendedor should be permittedto benefit" other defendants "not reasonably included among `those who play by the rules' or `take personal responsibility' or `pick up the tab' for the `skyrocketing]' costs of automobile insurance." (Hodges v. Superior Court, supra, 21 Cal.4th at p. 117, 86 Cal.Rptr.2d 884, 980 P.2d 433.) Hodges itself involved a products liability claim against the manufacturer of the car. In the absence of a clear expression of voter intent, we declined to adopt "a broad literal interpretation of the initiative" that would limit damages in such a claim, emphasizing that to do so would raise "`substantial policy concerns.' " (Id. at p. 118, 86 Cal.Rptr.2d 884, 980 P.2d 433.)