In October 2014, Keith and Tammie Jo Smith took a two-hour car ride from Pine Bluff, Arkansas to their home in Bastrop, Louisiana. According to a complaint filed in U.S. District Court, in Monroe Louisiana, as he exited his 2008 Chevrolet Suburban, Keith Smith put his hands on the driver’s seat and noticed that it seemed unusually hot to the touch. But, he never noticed it while driving, because an on-the-job injury had rendered Smith a paraplegic since July 1991.