In Kim v. Toyota Motor Corp., 243 Cal. App. 4th 1366 (Cal. Ct. App. 2016) (No. B247672), plaintiffs appealed from a jury verdict and judgment in favor of the defendant truck manufacturer in a case in which they alleged that the failure of the defendant to include electronic stability control in its pickup truck constituted a design defect. The Court of Appeal affirmed the decision of the trial court to limit the strict liability analysis to the risk benefit doctrine, and not analyze it under the consumer expectation test. The court also affirmed the trial court’s denial of plaintiffs’ motions seeking to exclude evidence that (a) the custom and practice in the pickup truck industry was not to include electronic stability control as a standard feature and (b) the pickup truck in question complied with the Federal Motor Vehicle Safety Standards, rejecting the argument that such evidence is never appropriate in a strict liability case. The court noted that recent decisions from the California Supreme Court acknowledge that similarities exist between negligence actions and strict liability actions evaluated under the risk benefit test and thus, the admissibility of such evidence was subject to the discretion of the trial court, which had not been abused.