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Hawkeye-Security Insurance v. Harnischfeger Corp.

Citations: 301 N.W.2d 846; 102 Mich. App. 190; 1980 Mich. App. LEXIS 3116Docket: Docket 45494

Court: Michigan Court of Appeals; December 2, 1980; Michigan; State Appellate Court

Narrative Opinion Summary

In a case involving a crane accident, the plaintiffs, comprised of an insurance company and an individual purchaser, successfully obtained a jury verdict for damages against the manufacturing corporation. The case centered on a crane's outrigger collapse shortly after delivery, attributed to both design and manufacturing defects, with expert testimony highlighting a bolt failure. The defendant argued for a directed verdict, invoking a precedent requiring proof of non-compliance with industry standards. However, the court differentiated this case due to the direct malfunction of a crane component, thus supporting the jury's inference of a manufacturer-related defect. Additionally, the defendant contested the propriety of certain jury instructions, which deviated from the Michigan Standard Jury Instructions. The court found these additional instructions to be appropriate and non-prejudicial, aligning with the legal standards and the parties' theories. Ultimately, the appellate court affirmed the trial court's decisions, dismissing the defendant's other claims of error, and awarded costs to the appellees, thereby reinforcing the plaintiffs' victory.

Legal Issues Addressed

Court's Discretion in Jury Instruction

Application: The court upheld that the trial judge's decision to provide additional instructions was within the discretion allowed under GCR 1963, 516.6(4), as these instructions correctly reflected the law and the parties’ theories.

Reasoning: GCR 1963, 516.6(4) allows courts to give additional instructions on relevant law not covered by SJI, provided they follow SJI's style.

Directed Verdict and Industry Standards

Application: The court held that the trial court properly denied the defendant's motion for a directed verdict, as the case involved a malfunction, distinguishing it from a precedent requiring compliance with industry standards.

Reasoning: Harnischfeger contended that the trial court wrongly denied its motion for a directed verdict based on their interpretation of a precedent, Owens v Allis-Chalmers Corp, which required plaintiffs to show that a design was non-compliant with industry standards.

Jury Instructions and Standard Jury Instructions

Application: The court found that the additional jury instructions given by the trial judge, which were not part of the Michigan Standard Jury Instructions, were appropriate and consistent with the law, thus not requiring reversal.

Reasoning: The court determined that the additional instructions were appropriate, non-argumentative, and did not require reversal based on Javis.

Product Liability and Design Defect

Application: The court determined that evidence of a design defect causing the crane's failure satisfied the plaintiffs' burden of proof, allowing the jury to reasonably infer a manufacturer-related defect.

Reasoning: The court concluded that evidence of a design defect causing the crane's failure met the plaintiffs' burden of proof, allowing the jury to reasonably infer a manufacturer-related defect.