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.

Tyco Electronics Corporation v. Illinois Tool Works, Inc.

Citation: Not availableDocket: 1-07-3539 Rel

Court: Appellate Court of Illinois; September 2, 2008; Illinois; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, Tyco Electronics Corporation filed a lawsuit against Illinois Tool Works, Inc. (ITW) following the failure of surge protection components supplied by ITW, which resulted in significant damages. Tyco sought damages exceeding $9 million under claims of breach of contract and warranties. However, the jury awarded Tyco only $2 million. Tyco appealed the decision, challenging the denial of its motion for a retrial focused solely on damages. The jury found ITW liable, but Tyco contended that the damages awarded were inconsistent with expert estimates. ITW argued that the failures were due to environmental conditions and Tyco's handling, not the product's initial quality. Tyco also argued that certain expert testimony violated legal rules such as the collateral source rule, but the court found no violation. The court also declined Tyco's request for a damages-only retrial, citing the intertwined nature of liability and damages in this case. Ultimately, the court affirmed the original judgment, determining that Tyco was given a fair trial and that the jury's verdict was supported by the evidence presented.

Legal Issues Addressed

Breach of Contract and Warranty Claims

Application: Tyco alleged that ITW breached express warranties and contractual obligations regarding the quality of surge protection components.

Reasoning: Tyco then sued ITW, claiming breach of contract and warranties.

Collateral Source Rule

Application: The court held that evidence presented did not violate the collateral source rule, as Sheets' testimony did not reference insurance compensation.

Reasoning: Sheets’ testimony did not reference Tyco’s insurance or its auditor, thereby not violating this rule.

Criteria for Damages-Only Retrial

Application: A damages-only retrial was deemed inappropriate due to the interconnectedness of liability and damages issues.

Reasoning: If the acts determining a defendant's liability also dictate the extent of damages, a separate damages-only retrial is inappropriate.

Denial of Motion for Retrial

Application: The trial court denied Tyco's motion for a retrial limited to damages, finding the jury's verdict consistent with the evidence presented.

Reasoning: Tyco sought a new trial limited to the damages issue, which the trial court denied.

Jury Verdict on Damages

Application: The jury awarded Tyco $2 million in damages despite Tyco's claim for over $9 million, reflecting a discrepancy between expert damage estimates and the jury's assessment.

Reasoning: The jury found ITW liable for breaching its contract and express warranties, awarding Tyco $2 million in damages.

Substantive Inadmissibility Doctrine

Application: The court ruled that there was no applicable rule requiring exclusion of Sheets' testimony based on allegedly inadmissible reports.

Reasoning: Tyco failed to identify a rule requiring the exclusion of the number of Superblock replacements Sheets used to calculate costs.