Adams v. Toyota Motor Corp.
867 F.3d 903 (2017)
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Rule of Law:
Evidence of other similar incidents (OSIs) is admissible in a product liability case to prove defect or causation if the proponent shows the incidents occurred under circumstances substantially similar to the one at issue. The proponent is not required to prove that the other incidents were caused by the exact same alleged defect.
Facts:
- On June 10, 2006, Koua Fong Lee was driving his 1996 Toyota Camry with his family on an interstate.
- As Lee exited the highway, he testified that he applied the brakes, but the car continued to accelerate on its own.
- The Camry, traveling at an estimated 75 miles per hour, failed to stop and rear-ended an Oldsmobile Ciera waiting at a red light.
- The collision killed Javis Trice-Adams, his six-year-old son Javis Jr., and his six-year-old niece Devyn Bolton, who died from her injuries approximately a year later.
- Two other passengers in the Oldsmobile, Quincy Adams and Jassmine Adams, were severely injured, as were the occupants of Lee's vehicle.
- Toyota had previously recalled several other models of the Camry for issues related to unintended acceleration, though the 1996 model driven by Lee was not among them.
Procedural Posture:
- Family members of the deceased filed a product liability lawsuit against Toyota in Minnesota state court.
- Koua Fong Lee subsequently joined the suit as a plaintiff.
- Toyota removed the case to the United States District Court for the District of Minnesota.
- Before trial, the district court denied Toyota's motion to exclude evidence of other similar incidents (OSIs), but limited the plaintiffs to three such witnesses.
- The district court also denied Toyota's motion to exclude the testimony of the plaintiffs' engineering expert.
- Following a trial, the jury returned a verdict finding Toyota 60 percent at fault and Lee 40 percent at fault, awarding the plaintiffs approximately $14 million.
- The district court entered judgment on the verdict but later reduced one plaintiff's award based on a prior settlement and awarded another prejudgment interest.
- Toyota appealed the judgment to the U.S. Court of Appeals for the Eighth Circuit, and plaintiff Bridgette Trice cross-appealed on the damages reduction.
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Issue:
In a product liability action, does the admission of evidence of other similar incidents require the proponent to establish that those incidents were caused by the same specific defect alleged to have caused the accident at issue?
Opinions:
Majority - Kelly, Circuit Judge
No. The admission of evidence of other similar incidents does not require proof of the same specific defect; rather, the incidents must have occurred under 'substantially similar circumstances.' The court found that the circumstances were substantially similar because each OSI witness drove the same model and year of car with similar high mileage, experienced unintended acceleration where the car maintained or increased speed after removing their foot from the gas pedal, and found the brakes to be ineffective in stopping the vehicle. The court reasoned that questions regarding the precise cause of the OSIs go to the weight the jury should assign the evidence, not its admissibility. The court also affirmed the admission of the plaintiffs' expert testimony, finding it was based on reliable methodology, and denied Toyota's motion for judgment as a matter of law, concluding a reasonable jury could find for the plaintiffs based on the evidence presented.
Analysis:
This decision reinforces the flexible 'substantially similar circumstances' standard for admitting evidence of other similar incidents in product liability cases within the Eighth Circuit. By rejecting a stricter requirement to prove identical causation for each incident, the court preserves significant discretion for trial judges in managing evidence. This approach benefits plaintiffs by allowing them to use circumstantial evidence of other product failures to strengthen their claims of defect and causation, forcing defendants to challenge the weight of such evidence through cross-examination rather than excluding it entirely.
