Earlier this month, a federal appellate court issued a written opinion that will likely be of interest to anyone considering an Indiana product liability lawsuit against a vehicle manufacturer. The case presented the court with the opportunity to answer two questions. First, it addressed whether the lower court was proper in dismissing the plaintiff’s case against the defendant vehicle manufacturer based on a perceived inconsistency in the jury’s verdict. And second, it addressed the issue of, if the plaintiff’s case was sufficient as a matter of law, whether the $1 million damages that the jury awarded him were adequate. Ultimately, the court resolved both questions in favor of the plaintiff.
The Facts of the Case
The plaintiff was injured in a roll-over accident when the van he was operating rear-ended another vehicle on the highway. While the initial collision was minor, the plaintiff was seriously injured when the van rolled, and he hit his head on the roof of the vehicle. After the accident, the plaintiff was permanently paralyzed from the neck down.
The plaintiff filed a product liability lawsuit against the vehicle’s manufacturer, making several claims. The plaintiff presented evidence showing that the manufacturer did not conduct any safety testing on the seatbelt mechanism in the van. The plaintiff also had an expert witness testify that, had testing been conducted, the results would have indicated that the seatbelt mechanism was unsafe, and the manufacturer would have likely used a safer mechanism in its place.
After the evidence was presented, the jury rejected each of the plaintiff’s claims except for one. Interestingly, the jury found that the vehicle was not defective or unreasonably dangerous, but the manufacturer was liable for not testing the seatbelt mechanism. The jury awarded the plaintiff just $1 million for past damages and nothing for future damages. The plaintiff filed a motion for a new trial as to damages, arguing that the jury’s verdict was inadequate.
In a post-trial motion, the defendant argued that the plaintiff failed to establish his case as a matter of law. The trial judge granted that motion, explaining that “the jury’s finding of no defect rendered the other finding of negligent failure to adequately test a legally insufficient basis for liability.” The trial judge then conditionally granted the plaintiff’s motion as well, in the event that an appellate court determined the plaintiff’s case was sufficient.
Both parties appealed. The plaintiff appealed the lower court’s finding that his case was insufficient as a matter of law. The manufacturer appealed the court’s conditional decision to conduct a new trial as to damages.
On appeal, both issues were resolved in favor of the plaintiff. The court explained that the plaintiff’s evidence was sufficient to establish that the manufacturer violated a duty of care it owed to the plaintiff and that this violation resulted in his injuries. The court also concluded that any perceived confusion on the part of the jury should be limited to the damages determination. Thus, the court reinstated the jury’s finding of fault against the van’s manufacturer and ordered that a new trial be conducted to determine the appropriate amount of damages.
Have You Been Injured in an Indiana Car Accident?
If you or a loved one has recently been injured in any kind of Indiana car accident, you may be entitled to monetary compensation. Car accidents can have a number of causes, and what initially seems like an accident that was caused by a motorist’s negligence may have actually been a result of a defective component in that motorist’s vehicle. The dedicated Indiana personal injury attorneys at the law firm of Parr Richey Frandsen Patterson Kruse have extensive experience handling all types of Indiana car accidents, and we know what it takes to be successful on our clients’ behalf. Call 888-532-7766 to schedule a free consultation with an attorney to discuss your case today.
Plaintiff’s Appeal Dismissed for Failure to Raise Issue at Trial, Indiana Injury Lawyer Blog, September 6, 2017
How Indiana’s Dram Shop Law Can Help Victims of Drunk Driving Accidents, Indiana Injury Lawyer Blog, August 8, 2017