You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Pfeifer v. John Crane, Inc.

Citation: Not availableDocket: B232315M

Court: California Court of Appeal; November 26, 2013; California; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This appellate case involves a lawsuit filed by a Navy veteran and his spouse against John Crane, Inc. (JCI) for negligence, strict liability, and loss of consortium due to asbestos exposure. The jury found JCI liable for 70% of the damages, awarding both economic and non-economic damages, including punitive damages. The appellate court affirmed the trial court's decisions, rejecting JCI's appeal on several grounds. The court upheld the punitive damages, finding substantial evidence of JCI's malice and conscious disregard for safety in failing to warn about asbestos hazards. It also affirmed the jury's fault apportionment, rejecting JCI's sophisticated user defense, as it lacked evidence to exempt JCI from its duty to warn the Navy. The court approved the calculation of settlement credits, which did not reduce JCI's liability for economic damages due to comparative fault. JCI's appeal on expert fees was dismissed for jurisdictional reasons. The judgment was modified to correct an error in the calculation of economic damages, ensuring they were not adjusted for JCI's comparative fault. The Pfeifers were awarded costs on appeal.

Legal Issues Addressed

Calculation of Settlement Credits

Application: Settlement credits were calculated without accepting the Pfeifers' proposed allocation, resulting in a reduction of economic damages without comparative fault adjustments.

Reasoning: The court ruled that all settlement funds were applicable to the trial claims, rejecting the Pfeifers' allocation.

Comparative Fault and Apportionment

Application: The jury's allocation of 70% fault to JCI was upheld due to insufficient evidence of Pfeifer's exposure from other sources, and comparative fault adjustments were applied only to noneconomic damages.

Reasoning: The jury found Pfeifer negligent but determined that his negligence was not a substantial factor in his injuries, assigning 70% of the fault to JCI.

Jurisdiction over Expert Fee Appeals

Application: JCI's appeal regarding expert fees was dismissed due to lack of jurisdiction as it failed to file a separate notice of appeal.

Reasoning: The court finds it lacks jurisdiction over JCI's challenge to the expert fees, as JCI's notice of appeal did not mention the motion to tax costs related to the expert fees.

Punitive Damages and Financial Condition Evidence

Application: The court upheld the punitive damages awarded, finding JCI's failure to warn customers about asbestos risks constituted malice, fraud, or oppression, and financial condition evidence was properly obtained post-liability.

Reasoning: The court found sufficient evidence of despicable conduct and conscious disregard for safety, as JCI failed to issue warnings despite its knowledge of the dangers.

Sophisticated User Defense

Application: The sophisticated user defense was rejected as JCI failed to provide sufficient evidence to show the Navy, as a sophisticated user, absolved JCI of its duty to warn.

Reasoning: JCI argued that the trial court wrongly dismissed its 'sophisticated user' defense, claiming that the Navy had greater knowledge of asbestos hazards than JCI.