Narrative Opinion Summary
In a diversity action against Ford Motor Company, the plaintiffs, R.R. and Barbara Anderson, alleged that a defective restraint system in their daughter's 1991 Ford Probe caused her fatal injuries in a car accident. Initially, a jury awarded the Andersons $700,000 in damages. However, the district court granted Ford's motion for a new trial, citing juror misconduct and unreliable expert testimony. Juror Dan Willis conducted unauthorized tests on the restraint system and discussed these with other jurors, against court instructions, impacting the verdict. Additionally, the testimony of the plaintiffs' expert, Dr. Peter Bertelson, was excluded due to his lack of knowledge about the specific vehicle’s anchor placement, rendering his opinion unscientific. In a subsequent trial, the jury returned a verdict in favor of Ford. The Andersons appealed the decision to grant a new trial, but the appellate court affirmed, agreeing with the lower court's findings on juror misconduct and choosing not to address the exclusion of Dr. Bertelson's testimony. The appellate court's decision was based on the prejudicial impact of the misconduct, as reviewed under Federal Rule of Evidence 606(b).
Legal Issues Addressed
Appellate Review of Juror Misconductsubscribe to see similar legal issues
Application: The appellate court reviewed the district court's handling of juror misconduct for abuse of discretion, ultimately agreeing that the misconduct was prejudicial and warranted a new trial.
Reasoning: The appellate court reviewed the district court's handling of the juror misconduct for abuse of discretion. It noted that in civil cases, a new trial is warranted only if extraneous materials are shown to be prejudicial.
Expert Testimony Reliabilitysubscribe to see similar legal issues
Application: The district court excluded the testimony of Dr. Bertelson, an expert witness for the plaintiffs, due to his lack of knowledge about the specific vehicle's anchor placement, rendering his opinion unscientific.
Reasoning: The district court determined that expert Dr. Bertelson's testimony about the restraint system being defective was unreliable due to his lack of knowledge regarding the specific vehicle's anchor placement, rendering his opinion unscientific and prejudicial.
Federal Rule of Evidence 606(b)subscribe to see similar legal issues
Application: The court applied Federal Rule of Evidence 606(b) to consider juror testimony about extraneous information impacting the verdict, finding it sufficient to affirm the order for a new trial.
Reasoning: The Andersons argued there was no proof of such prejudice, but the court disagreed, citing Federal Rule of Evidence 606(b) regarding juror testimony on extraneous information.
Juror Misconduct in Civil Trialssubscribe to see similar legal issues
Application: The appellate court affirmed the district court's decision to grant a new trial due to juror misconduct involving unauthorized testing of evidence, which was considered prejudicial against the defendant.
Reasoning: The court found that juror Mr. Willis conducted an unauthorized test related to the case, which was a controlling issue, and used this test to influence his opinion.