Martin v. Volvo Cars of North America, Inc.
Docket: Appeal No. 1
Court: Appellate Division of the Supreme Court of the State of New York; July 3, 1997; New York; State Appellate Court
The cross appeal was unanimously dismissed, and the judgment was reversed with costs awarded to the plaintiffs, leading to the granting of a new trial. The plaintiff, Melanie R. Martin, experienced severe injuries after her Volvo struck a deer, causing the hood to open and obstruct her view, resulting in her head striking the steering wheel. Post-accident, she developed severe headaches, vomiting, disorientation, and communication issues, ultimately leading to her inability to continue her high-level job. In her lawsuit against Volvo Cars of North America, Inc. and Volvo Car Corporation, she claimed damages for her injuries, while her husband brought a derivative claim. At trial, evidence indicated that a defectively manufactured hood latch caused the accident and her injuries. The plaintiffs presented medical evidence linking her head injury to a brain injury and resulting disability. In contrast, the defendants argued that her condition stemmed from a conversion disorder, suggesting that her preexisting mental fragility led to her disability independent of the accident. The jury concluded that there was a manufacturing defect but determined it was not a substantial cause of the plaintiff's injuries. The Supreme Court incorrectly denied the plaintiffs' request to instruct the jury on the liability of defendants for activating a latent condition due to negligence. This legal doctrine allows for recovery even if a preexisting condition was exacerbated by a negligent act. Defendants could not simultaneously argue that the plaintiff's disability was solely due to her latent condition while denying the jury the opportunity to consider whether the accident triggered it. The court found that the jury instructions failed to adequately reflect both parties' factual contentions, leading to jury confusion. Consequently, the judgment was reversed, and a new trial was ordered.