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Crocker v. Exteriors

Citations: 857 So. 2d 795; 2003 Ala. LEXIS 75Docket: 1020298

Court: Supreme Court of Alabama; March 6, 2003; Alabama; State Supreme Court

Narrative Opinion Summary

Gary Crocker, as the administrator of Shirley Crocker's estate, has failed to adequately establish the factual basis for his claim against Fulton Performance Products, Inc. under the Alabama Extended Manufacturer’s Liability Doctrine, as required by precedent set in Ex parte Dorsey Trailers, Inc. 397 So.2d 98, 104 (Ala.1981). Until Crocker provides evidence of the alleged defect, the evidence that Fulton seeks through disassembly of the trailer hitch may not be relevant. At this point in the proceedings, Fulton has not demonstrated that the trial court acted outside its discretion by denying the request for disassembly.

Legal Issues Addressed

Alabama Extended Manufacturer’s Liability Doctrine

Application: The plaintiff must establish a factual basis for the claim against the manufacturer, in accordance with established legal precedents.

Reasoning: Gary Crocker, as the administrator of Shirley Crocker's estate, has failed to adequately establish the factual basis for his claim against Fulton Performance Products, Inc. under the Alabama Extended Manufacturer’s Liability Doctrine, as required by precedent set in Ex parte Dorsey Trailers, Inc. 397 So.2d 98, 104 (Ala.1981).

Relevance of Evidence in Product Liability Claims

Application: Evidence sought through disassembly is deemed irrelevant until the plaintiff provides evidence of the alleged defect in the product.

Reasoning: Until Crocker provides evidence of the alleged defect, the evidence that Fulton seeks through disassembly of the trailer hitch may not be relevant.

Trial Court Discretion in Evidence Discovery

Application: The trial court's discretion in denying requests for evidence discovery, such as disassembly, is upheld unless it is shown to exceed judicial discretion.

Reasoning: At this point in the proceedings, Fulton has not demonstrated that the trial court acted outside its discretion by denying the request for disassembly.