Nahmias, Presiding Justice.

Parks, Chesin & Walbert, David F. Walbert, Jennifer K. Coalson ; Cochran & Edwards, R. Randy Edwards, Paul A. Piland ; Sherrod & Bernard, John W. Sherrod, for appellants.

King & Spalding, Chilton D. Varner, Susan M. Clare, for appellees.

John D. Hadden ; Balch & Bingham, James D. Meadows, James L. Hollis, Malissa A. Kaufold- Wiggins, Patrick N. Silloway ; Chambless, Higdon, Richardson, Katz & Griggs, David N. Nelson ; Drew, Eckl & Farnham, Elissa B. Haynes ; Ellis Painter Ratterree & Adams, Philip M. Thompson, amici curiae.

Nahmias, Presiding Justice. We granted this petition for certiorari to decide whether OCGA § 51-12-33 (a) applies to a strict products liability claim under OCGA § 51-1-11. The Court of Appeals held that strict products liability claims are subject to such apportionment. See Suzuki Motor of America v. Johns , 351 Ga. App. 186, 198, 830 S.E.2d 549 (2019). For the reasons discussed below, we agree, so we affirm.

1. The facts of this case are detailed throughout the Court of Appeals opinion, and we will merely summarize them as pertinent here. Adrian Johns was seriously injured in August 2013 when the front brake on his Suzuki motorcycle failed suddenly. He sued the designer and manufacturer of the motorcycle, Suzuki Motor Corporation ("SMC"), and its wholly-owned subsidiary and American distributor, Suzuki Motor of America, Inc. ("SMAI") (collectively, "Suzuki"), asserting a claim of strict products liability based on a design defect and two negligence claims (breach of a continuing duty to warn and negligent recall). Adrian's wife, Gwen Johns, also sued Suzuki, alleging loss of consortium.

The case proceeded to trial, where the Johnses presented evidence showing that the brake failure of Adrian's motorcycle was caused by a defect in the design of the front master brake cylinder that created a corrosive condition, which resulted in a "leak path" that misdirected the flow of brake fluid and caused the total brake failure. About two months after Adrian's accident, Suzuki issued a recall notice warning about a safety defect in the front brake master cylinder. Suzuki had notice of the issue, including reports of similar accidents, for a significant amount of time before Adrian's accident. Adrian admitted, however, that contrary to the instructions in the owner's manual to replace the brake fluid every two years, he had not changed the fluid during the eight years he had owned the motorcycle.

The jury found in favor of the Johnses on all claims. It awarded $10.5 million in compensatory damages to Adrian and another $2 million to Gwen. The jury apportioned 49% of the fault to Adrian and 51% to the two defendants – 45% to SMC and 6% to SMAI. In light of these findings, the trial court reduced Adrian's award to $5,355,000 and Gwen's award to $1,020,000. Because the damages after apportionment were less than the Johnses’ pretrial demand of $10 million, the trial court rejected the Johnses’ request for pre-judgment interest under OCGA § 51-12-14 (a).

The Johnses cross-appealed, arguing that because their claim was based on strict products liability, the trial court erred in reducing the damages awards based on OCGA § 51-12-33 (a), and therefore also erred in failing to award them pre-judgment interest. The Court of Appeals affirmed the trial court's rulings. See Suzuki Motor , 351 Ga. App. at 198-199 & n.5, 830 S.E.2d 549. As explained below, the Court of Appeals did so correctly.

2. The current version of OCGA § 51-12-33 was enacted in 2005. See Ga. L. 2005, p. 1, § 12. As particularly relevant to the issue presented in this case, subsection (a) of § 51-12-33 says:

Where an action is brought against one or more persons for injury to person or property and the plaintiff is to some degree responsible for the injury or damages claimed, the trier of fact, in its determination of the total amount of damages to be awarded, if any, shall determine the percentage of fault of the plaintiff and the judge shall reduce the amount of damages otherwise awarded to the plaintiff in proportion to his or her percentage of fault.

Subsection (g) says:

Notwithstanding the provisions of this Code section or any other provisions of law which might be construed to the contrary, the plaintiff shall not be entitled to receive any damages if the plaintiff is 50 percent or more responsible for the injury or damages claimed.

We have said that these two subsections together "codify the doctrine of comparative negligence." Zaldivar v. Prickett , 297 Ga. 589, 594, 774 S.E.2d 688 (2015).

As the Court of Appeals recognized, "by its plain terms, the statute governs actions ‘for injury to person,’ without in any way distinguishing between the theories upon which those claims are premised." Suzuki Motor , 351 Ga. App. at 198, 830 S.E.2d 549. The Johnses’ strict products liability claim is "an action ... brought against one or more persons [SMC and SMAI] for injury to person [Adrian]." OCGA § 51-12-33 (a). Thus, the strict products liability claim falls comfortably within the statute's textual ambit. See Fed. Deposit Ins. Corp. v. Loudermilk , 305 Ga. 558, 562, 826 S.E.2d 116 (2019) (explaining that "a statute draws its meaning ... from its text," and "we must read the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would" (citations and punctuation omitted)).

The Johnses argue that OCGA § 51-12-33 (a) does not apply because neither that provision nor the preamble to the 2005 act of which it was a part expressly mentions strict products liability. But it is not necessary for the statute (much less its preamble) to recite "strict products liability" to encompass strict products liability claims like Adrian's within its broad, and by all appearances applicable, language. See Couch v. Red Roof Inns , 291 Ga. 359, 361-363, 729 S.E.2d 378 (2012) (applying OCGA § 51-12-33 to intentional tortfeasors not because the statute mentions them but because "the ordinary meaning of ‘fault’ ... includes intentional conduct," explaining that "a thing need not be defined into a class that already includes it").

3. The Johnses further argue that even if the language of OCGA § 51-12-33 (a) would otherwise apply to their claim, we should read into the statute an exception for strict products liability claims, based on a line of Georgia precedent holding that principles of comparative negligence do not apply to such claims. That precedent, however, was supplanted by OCGA § 51-12-33 (a) and (g).

Georgia's strict products liability statute, OCGA § 51-1-11, was originally enacted in 1968. See Ga. L. 1968, p. 1166. OCGA § 51-1-11 (b) (1) says:

The manufacturer of any personal property sold as new property directly or through a dealer or any other person shall be liable in tort, irrespective of privity, to any natural person who may use, consume, or reasonably be affected by

the property and who suffers injury to his person or property because the property when sold by the manufacturer was not merchantable and reasonably suited to the use intended, and its condition when sold is the proximate cause of the injury sustained.

"The paramount purpose of strict liability is the protection of otherwise defenseless victims of manufacturing defects and the spreading throughout society of the cost of compensating them." Farmex Inc. v. Wainwright , 269 Ga. 548, 550, 501 S.E.2d 802 (1998) (citation and punctuation omitted). To advance these goals, strict products liability "imposes liability irrespective of negligence." Ford Motor Co. v. Carter , 239 Ga. 657, 660, 238 S.E.2d 361 (1977) (plurality opinion). See also Alexander v. General Motors Corp. , 267 Ga. 339, 340, 478 S.E.2d 123 (1996) ("[A] strict liability claim in Georgia ... eliminates questions of negligence and the usual defenses to negligence."); Ellis v. Rich's, Inc. , 233 Ga. 573, 576, 212 S.E.2d 373 (1975) ("Essentially the doctrine of strict liability eliminates questions of negligence in tort actions.").

A number of cases from this Court and the Court of Appeals have held that a plaintiff's negligence generally is not a defense to a claim of strict products liability. See Deere & Co. v. Brooks , 250 Ga. 517, 518, 299 S.E.2d 704 (1983) (" ‘[T]he case law generally is in accord with the Restatement of Torts in holding that contributory negligence is not a defense to a claim of strict liability for product-caused harm.’ " (citation omitted) (referring to Restatement (Second) of Torts § 402A (1965) ); Ford Motor Co. , 239 Ga. at 661 n.3, 238 S.E.2d 361 (plurality opinion) ("Contributory negligence on the part of the injured party is generally not available as a defense in strict liability actions."); Ray v. Ford Motor Co. , 237 Ga. App. 316, 319-320, 514 S.E.2d 227 (1999) ; Barger v. Garden Way, Inc. , 231 Ga. App. 723, 727, 499 S.E.2d 737 (1998) ; Continental Research Corp. v. Reeves , 204 Ga. App. 120, 128, 419 S.E.2d 48 (1992) (physical precedent only); Parzini v. Center Chem. Co. , 136 Ga. App. 396, 399, 221 S.E.2d 475 (1975). Although the Johnses would like to rely on the precedent established by these cases, all of the cases were decided before the 2005 enactment of OCGA § 51-12-33 (a) and (g). There is no question that statutes can displace decisional law. See Couch , 291 Ga. at 364, 729 S.E.2d 378 ("[A]s long as legislation does not violate the Constitution, when the Legislature says something clearly – or even just implies it – statutes trump cases."). In fact, we have held that the very statute at issue here supplanted the common law prohibiting apportionment to intentional tortfeasors. See id. at 364-365, 729 S.E.2d 378. Given the clear and broad language of OCGA § 51-12-33, we conclude, as the Court of Appeals did, that the statute supplanted the nocomparative-negligence holdings of the pre-2005 cases on which the Johnses rely. See Suzuki Motor , 351 Ga. App. at 198, 830 S.E.2d 549.

4. The Johnses offer a few more arguments as to why, in their view, the precedent rejecting comparative negligence for strict products liability claims must survive OCGA § 51-12-33. None of those arguments is persuasive.

(a) The Johnses suggest that we cannot now hold that OCGA § 55-12-33 (a) and (g) displace the decisional law rule about comparative negligence and strict products liability claims because when we said in Zaldivar that OCGA § 55-12-33 (a) and (g) "codify the doctrine of comparative negligence," 297 Ga. at 594, 774 S.E.2d 688, we were holding that the statute preserved any and all limitations on comparative negligence. That is an overbroad reading of Zaldivar . We obviously did not in that case consider and endorse every holding about comparative negligence that had ever been issued by a Georgia court. Rather, we were speaking only of the general principle of comparative negligence, which is textually reflected in OCGA § 51-12-33 (a) and (g).

(b) The Johnses contend that the pre-2005 case law was affirmed by the Court of Appeals in Patterson v. Long , 321 Ga. App. 157, 741 S.E.2d 242 (2013), and we should follow Patterson . In that case, which involved review of an arbitrator's award, the Court of Appeals said:

Both parties agree that if liability is imposed upon a defendant manufacturer under the doctrine of strict liability, principles of contributory and comparative negligence are inapplicable, and fault should not be apportioned between the plaintiff victim and the defendant manufacturer in awarding damages.

Id. at 161, 741 S.E.2d 242 (citing Deere , 250 Ga. at 518, 299 S.E.2d 704, and Ford Motor Co. , 239 Ga. at 662, 238 S.E.2d 361 ). This statement was not a reasoned consideration of OCGA § 51-12-33 ’s effect on the pre-2005 case law. Instead, Patterson simply restated the parties’ agreement on the issue without acknowledging the existence of, much less analyzing, § 51-12-33. Moreover, Patterson ’s statement was dicta, as the court decided the case based on the standard for review of an arbitrator's decision. See id. at 165-166, 741 S.E.2d 242. Thus, Patterson is not persuasive on the question we decide today, and to the extent that case indicates that the decisions prohibiting the application of comparative negligence to strict products liability claims survived the 2005 enactment of § 51-12-33, we disapprove it.

The Johnses also point to Hernandez v. Crown Equipment Corp. , Civil Action No. 7:13-CV-91 (HL), 2015 WL 4067695 (M.D. Ga. July 2, 2015), in which a federal district judge said, relying primarily on Patterson :

The state of the law is clear in Georgia: where a defendant manufacturer is found liable under the doctrine of strict liability, the principle of comparative negligence does not apply, and it is not appropriate to

apportion fault between the plaintiff victim and the defendant manufacturer.

Hernandez , 2015 WL 4067695, at *2. The Hernandez court acknowledged OCGA § 51-12-33 (a), but concluded that Patterson and the pre-2005 cases on which it relied prohibited the application of the statute to a strict products liability claim. The court did not appear to contemplate the possibility that § 51-12-33 (a) had supplanted the decisional law that Patterson injudiciously cited in support of its dicta. The district court's ruling was affirmed by the Eleventh Circuit in an unpublished decision with no further analysis and no mention at all of § 51-12-33. See Hernandez v. Crown Equip. Corp. , 649 Fed. Appx. 726, 730 (11th Cir. 2016) ("Under Georgia law, contributory negligence is not a defense to a products liability claim." (citing Deere , 250 Ga. at 518, 299 S.E.2d 704 )). The decisions of federal courts do not control this Court's interpretation of Georgia law. See Barrow v. Raffensperger , 308 Ga. 660, 689 n.27, 842 S.E.2d 884 (2020). And, given the shortcomings in their analyses, the Hernandez decisions are not persuasive.

By contrast, when another federal district judge more carefully considered OCGA § 51-12-33 and its effect on strict products liability claims, the court recognized that the statement about comparative negligence in Patterson was dicta "that relies upon common law predating the enactment of [ OCGA § 51-12-33 ]" and that this Court's analysis in Couch "does not support this Court of Appeals dicta." Bullock v. Volkswagen Group of America , Case No. 4:13-CV-37 (CDL), 2015 WL 5319791, at *1 (M.D. Ga. Sept. 11, 2015). Understanding that Couch read § 51-12-33 (a) ’s plain language as "not restrict[ing] its application to a particular type of action," the court concluded:

[ OCGA § 51-12-33 ] provides no exception for actions based on a theory of strict liability. And a plain reading of the statute does not reveal any intention to exclude strict liability

actions from its application. The statute simply and clearly provides that it applies to actions "brought against one or more persons for injury to person or property [where] the plaintiff is to some degree responsible for the injury or damages claimed." Id. To the extent that the application of the comparative fault statute to a strict liability product defect claim may be inconsistent with the common law that predated the enactment of the statute, the Georgia General Assembly certainly had the authority to displace that common law.

Bullock , 2015 WL 5319791, at *2. This reasoning is more fulsome and more persuasive, and it reaches the same conclusion we do today.

(c) The Johnses also assert that allowing comparative negligence to be considered will effectively eliminate the claim of strict products liability, and the General Assembly could not have intended to make such a "radical" change sub silentio. Permitting comparative negligence to be applied to strict products liability claims does not, however, mean the end of strict products liability. OCGA § 51-12-33 (a) and (g) do not conflict with OCGA § 51-1-11. Plaintiffs raising strict products liability claims will still generally be relieved of the burden of showing that the injury-causing product defect was the result of the manufacturer's negligence.

The Johnses assert that the benefit the plaintiff derives from not having to prove the manufacturer's negligence is undermined by injecting any consideration of negligence into a strict products liability claim. See Alexander , 267 Ga. at 340, 478 S.E.2d 123 (stating that Georgia's strict products liability claim "eliminates questions of negligence and the usual defenses to negligence"). But considering a plaintiff's responsibility for an injury does not require proof of the manufacturer's negligence. Indeed, although the doctrine is commonly called "comparative negligence," it does not present the same kind of negligence question that would be presented about a manufacturer in a traditional negligence case.

It has been suggested that the term "contributory negligence[ ]" ... may indeed itself be a misnomer since it lacks the first element of the classical negligence formula, namely, a duty of care owing to another. A highly respected torts authority, Dean William Prosser, has noted this fact by observing, "It is perhaps unfortunate that contributory negligence is called negligence at all. ‘Contributory fault’ would be a more descriptive term.

Daly v. Gen. Motors Corp. , 20 Cal.3d 725, 144 Cal.Rptr. 380, 575 P.2d 1162, 1167-1168 (1978).

This understanding is especially helpful when we consider OCGA § 51-12-33, which is not framed in terms of "negligence," but instead focuses on the plaintiff's "responsib[ility]" and "fault" for the injury claimed. OCGA § 51-12-33 (a) and (g). As we explained in Couch , "fault is not meant to be synonymous with negligence." 291 Ga. at 362, 729 S.E.2d 378. See also Zaldivar , 297 Ga. at 594, 774 S.E.2d 688 (" ‘[F]ault’ – at least as the term is used in subsection (a) with respect to a plaintiff – refers to a breach of the legal duty that a plaintiff owes to exercise ordinary care to avoid injury to himself that is a proximate cause of the injury for which he now seeks to recover damages from a defendant."). Thus, comparative negligence – which is really comparative fault – is not incompatible with a strict products liability claim.

Some courts have noted that "comparing [a] plaintiff's fault with a product defect is no easy task." Restatement (Third) of Torts: Products Liability § 17, reporters’ note on comment a. (1998) (collecting cases). But difficult is not the same as impossible, and we have previously expressed our faith in the ability of juries to compare disparate types of fault. See Couch , 291 Ga. at 365-366, 729 S.E.2d 378 (requiring jurors to apportion fault between negligent and intentional tortfeasors). In Loudermilk , we held that the commonlaw principle of joint and several liability for "traditional concerted action" survived OCGA § 51-12-33 ’s imposition of apportionment in actions for injury to person or property because "fault in such [concerted-action] scenarios is not divisible." Loudermilk , 305 Ga. at 576, 826 S.E.2d 116. The Johnses seek to rely on that holding to preserve the cases rejecting comparative negligence in strict products liability. That reliance is unfounded, because the application of comparative negligence is possible in strict products liability claims, where manufacturers and consumers of products are not engaged in traditional concerted action.

(d) Finally, the Johnses argue that holding manufacturers absolutely liable is a fundamental tenet of strict products liability, so allowing their responsibility to be reduced or eliminated based on the plaintiff's fault undermines the policy behind strict products liability. There is a policy argument that the protection of consumers is so important that it should extend to ignoring their contribution to injuries caused by defective products. On the other hand, some courts and scholars "have argued that it is unwise to relieve users and consumers of all responsibility for safe product use and consumption." Restatement (Third) of Torts: Products Liability § 17, reporters’ note on comment a. (1998). See also Daly , 144 Cal.Rptr. 380, 575 P.2d at 1169 ("[W]e do not permit plaintiff's own conduct relative to the product to escape unexamined, and as to that share of plaintiff's damages which flows from his own fault we discern no reason of policy why it should ... be borne by others."); Smith v. Goodyear Tire & Rubber Co. , 600 F.Supp. 1561, 1568 (D. Vt. 1985) ("Although we would be reluctant to completely excuse defendants simply because some of a plaintiff's injuries might have resulted from his own actions, it also does not seem fair to allow a negligent plaintiff, who may have contributed to as much as fifty percent of his injuries, to pay for none of them and to recover as much as a plaintiff who had taken all precautions reasonable under the circumstances."). In balancing these competing policy considerations, the General Assembly chose to enact OCGA § 51-12-33 (a) and (g).

5. For the reasons explained above, we are not persuaded that we should ignore the plain language of OCGA § 51-12-33 (a) and write into the statute an exception for strict products liability claims. The Court of Appeals did not err by concluding that the statute applies in this case, and the trial court did not err by reducing the Johnses’ damages awards based on Adrian's fault and not awarding pre-judgment interest.

Judgment affirmed.

All the Justices concur, except Peterson, J., who concurs except as to footnotes 7, 8, and 9, and Blackwell and Warren, JJ., not participating.