Over the last several years, the number of fatalities due to car accidents has increased despite the fact that cars are safer than ever. One cause for this is distracted driving due to drivers talking or texting on their cell phones while driving. There is technology available that will automatically disable a driver's cell phone while it is in motion in a car or airplane.

Should a person, who is injured by a driver that is texting while driving, be allowed to sue the cell phone manufacturer under a products liability theory of liability?