On August 1, 2025, a Florida jury returned a verdict totaling $243,000,000 against Tesla, Inc. in the consolidated cases Neima Benavides v. Tesla and Dillon Angulo v. Tesla.¹ These cases caught public attention because of the magnitude of the verdict, the “Autopilot” technology at issue and, perhaps, interest in Tesla's Chief Executive Officer and Technoking, Elon Musk.²

The case arose from a traffic accident that resulted in the death of Naibel Benavides Leon, age 22, and serious injury to her boyfriend, Dillon Angulo. At the time of the accident, George McGee was driving his 2019 Tesla Model S. As McGee approached a T-intersection marked with a stop sign and a flashing light, he failed to notice Benavides Leon and Angulo standing near their parked car. McGee admitted that he was distracted at the time of the crash because he dropped his cell phone and was reaching for it.

Plaintiffs’ lawyers contended that Tesla's Autopilot capabilities were exaggerated and caused drivers, including McGee, to be inattentive, thus causing the accident. In the specific case at issue, Plaintiffs' lawyers also argued that the Autopilot technology was defective because the car failed to recognize the parked vehicle and engage the brake. The jury agreed and concluded that the defect was a legal cause of the harm to Benavides Leon and Angulo. However, the jury also found McGee's negligence was a legal cause of that harm.³

The case docket sheds light on some of the strategies taken by the parties. For example, Plaintiffs' attorneys sought to introduce various statements made by Musk that supposedly overstated the use of and reliability of Tesla's Autopilot technology. However, the Court chastised Plaintiffs for being “misleading” and “manipulative” by taking those statements out of context. Tesla sought to exclude evidence of other accidents involving its Autopilot technology on the basis that those accidents were not sufficiently similar to have probative value in this case. The Court disagreed. The case docket reflects that every pre-trial battle was fought with vigor by both sides.

Tesla maintained throughout the case its position that the Autopilot technology was never intended as a substitute for human judgment and attention to the task of driving. At the same time, Tesla's own descriptions of its Autopilot features make bold claims.⁴

Was the Punitive Damages Award Nuclear?

The jury concluded McGee's negligence was 67% responsible for the accident, and Tesla's was 33%. Benavides Leon's parents were awarded a combined $59,000,000 for their pain and suffering as a result of the loss of their daughter. Angulo was awarded a total $70,000,000 related to his injuries.

Most commentary on the verdict focuses on the “nuclear” nature of the $200,000,000 punitive damages award against Tesla. A nuclear verdict is loosely defined as one that exceeds reasonableness.

To award punitive damages, the jury was required to find by “clear and convincing evidence” that Tesla was guilty of intentional misconduct or gross negligence. “Intentional misconduct” means that Tesla had actual knowledge of the wrongfulness of its conduct and that there was a high probability of injury or damage to Plaintiffs and, despite that knowledge, Tesla intentionally pursued its course of conduct. “Gross negligence” means that Tesla’s conduct was so reckless or wanting in care that it constituted a conscious disregard or indifference to the life, safety, or rights of persons exposed to the conduct.⁵

The jury was instructed that an award of punitive damages should be sufficient to punish, and that it should consider Tesla's knowledge of the danger, the degree of its misconduct, and its financial resources. The jury was also instructed that it could not award an amount that would financially destroy Tesla. The jury deliberated for about 7 hours before returning its verdict, which included the $200,000,000 punitive damages award against Tesla.

As of August 2025, various business and online sources estimate Tesla's value at about One Trillion Dollars.⁶ The jury's punitive damages award of $200 Million is .0002%, or two ten-thousandths of one percent of Tesla's value. When considered this way, it is difficult to conclude that the award is unreasonable or irrational, or “nuclear.” Whatever one's view, the punitive damages award in the Tesla case is not an example from which conclusions should be drawn about nuclear verdict trends because of the specific defect at issue in the case and Tesla's extraordinary high net value as a company.

Autonomous Vehicles and the Trucking Industry

Autonomous trucks are in the “on the road” testing phase in states such as Texas, where Aurora Innovation, Inc. has taken the lead in the development of self-driving trucks, with companies such as Kodiak Robotics, Waymo, TuSimple, Gatik and Einride joining the race. Some of these companies focus on long-haul routes, while others are looking to fill the need presented by shorter, repetitive delivery routes. Unlike Tesla's Autopilot technology (as it exists today and with its admonition that an attentive driver is required for its proper use), these trucking technology companies are looking to a future where trucks are truly autonomous without any human oversight while on the road.

Aurora's autonomous product is called “Aurora Driver for Freight.”⁷ While on the road testing is in progress, Aurora also uses closed-course tests and simulators as it continues to train its trucks to recognize such things as differences between pedestrians who are standing, crouching or lying down. Among other things, Aurora asserts that autonomous trucks will improve safety because an average human driver may encounter a roadway collision only a few times during a lifetime, while Aurora Driver has experienced millions of collision scenarios through simulation. In this regard, Aurora seems correct. What is less clear, however, is how millions of collision scenarios add the element of human judgment and decision-making in the space of a single, critical moment.

Trucking companies have been using artificial intelligence tools to improve their operations for a significant period of time. Much like passenger cars, trucking companies use tools such as route optimization, predictive maintenance systems, automated braking, lane monitoring and driver fatigue detection. Cameras focused on exterior traffic conditions and interior (cab) conditions are commonplace in the trucking industry and some insurers require these tools.

While innovation is both exciting and inevitable, a fully loaded semi-truck, including cargo, tractor and trailer can lawfully weigh up to 80,000 pounds.⁸ Passenger cars range from 2,500 pounds to over 6,000 pounds for SUVs and large trucks. With well-publicized cases such as Tesla, earning the trust of the public will be critical to developing and implementing autonomous truck technology that is sufficiently safe to avoid the next “nuclear” verdict, which can only come because of a catastrophic collision. Given the power and weight of freight trucks, the potential for harm resulting from defects in the technology is increased exponentially.

In the case of a truly autonomous truck, the human driver will not be apportioned two-thirds of the fault, as was true in the Tesla case — the technology will be to blame. While it is clear that truly autonomous and safe freight trucks are not likely in the immediate future, technology advances rapidly and the potential benefits of autonomous trucking in the commercial landscape may exceed the bounds of human imagination.

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¹ United States District Court, Southern District of Florida, Case No. 1:21-cv-21940.

² Musk registered the latter as his official title with the Securities and Exchange Commission in 2021.

³ Jury Verdict Form, Case Document 534, entered August 1, 2025.

⁴ https://www.tesla.com/support/autopilot#do-all-vehicles

⁵ Jury Instructions, Case Document 536, entered August 4, 2025.

⁶ For example, Marketcap, Macrotrends, Forbes, and Visual Capitalist.

⁷ Aurora offers its own "Driverless Safety Report 2025."

⁸ Department of Transportation: Exhibit 2, National Network Vehicle Size and Weight Standards.