John Haugh v. Jones & Laughlin Steel Corporation
1991 WL 243575, 1991 U.S. App. LEXIS 27445, 949 F.2d 914 (1991)
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Rule of Law:
Federal Rule of Evidence 606(b) prohibits a judge from questioning jurors about the effect an unauthorized communication had on their deliberations; the judge must instead objectively determine if a reasonable possibility of prejudice exists. In a negligence action, a party that voluntarily undertakes an activity assumes a duty to perform it with reasonable care, and a plaintiff is generally not contributorily negligent for failing to anticipate and guard against another's negligence.
Facts:
- Jones & Laughlin Steel Corporation (J&L) contracted with Eichleay Corporation to perform repair work at J&L's steel mill.
- John Haugh, an Eichleay employee, was tasked with removing and replacing large generators and steel shafts.
- Although Eichleay's contract gave it responsibility for this work, it was the regular practice for J&L employees to perform the preliminary rigging of equipment for removal.
- On the day of the accident, J&L employees rigged a nearly one-ton steel shaft for Haugh to remove, using a chain hoist and a cable (a 'choke').
- The J&L employees failed to properly tighten the cable, leaving it loose around the shaft and unable to secure it.
- Haugh, not noticing the defective rigging, proceeded to remove the remaining bolts connecting the shaft.
- When Haugh operated the chain hoist to lift the shaft, it slipped out of the loose cable and fell on him, severely injuring his arm.
- Haugh later acknowledged in testimony that he would have seen the defect if he had looked closely at the rigging.
Procedural Posture:
- John Haugh sued Jones & Laughlin Steel Corp. (J&L) in federal district court for negligence.
- The first trial concluded with a jury verdict for Haugh in the amount of $85,000.
- Following the verdict, the district judge learned of an improper communication made by a court marshal to the jury during its deliberations.
- The district judge held a hearing and, finding a reasonable possibility that the communication had influenced the verdict, granted J&L's motion for a new trial.
- During a second trial, at the close of all evidence, the district judge granted J&L's motion for a directed verdict on the grounds that J&L owed no duty and Haugh was contributorily negligent.
- Haugh, the plaintiff-appellant, appealed the grant of the new trial and the directed verdict to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Is a worker contributorily negligent as a matter of law for failing to inspect equipment that was negligently prepared by another company's employees, thereby precluding recovery for injuries caused by that negligence?
Opinions:
Majority - Posner
No. A worker is not contributorily negligent as a matter of law for failing to take precautions against the negligence of others; whether such failure amounts to negligence is a question of fact for a jury. The court reasoned that J&L, by voluntarily undertaking the task of rigging the shaft, assumed a duty to perform that task with reasonable care, regardless of its contractual obligations. The plaintiff's duty is to exercise due care, but that does not ordinarily require a person to anticipate and take precautions against another party's negligence. Haugh's admission that he could have discovered the defect does not automatically make him contributorily negligent, as this would improperly shift the burden of care from the careless party (J&L's riggers) to the careful one (the victim). While an exception exists for dangers that are so great or so easily averted that self-protection is required, whether this case fits that exception is a matter for a jury to resolve. Therefore, the district court erred in granting a directed verdict.
Analysis:
This decision significantly clarifies the boundary between questions for the judge and questions for the jury regarding contributory negligence. It establishes that a defendant cannot easily win on a directed verdict by arguing the plaintiff 'could have' been more careful; the key issue for the jury is whether the plaintiff's conduct was reasonable under the circumstances. The ruling also sets a firm precedent regarding Federal Rule of Evidence 606(b), strictly limiting judicial inquiry into jury deliberations to the existence and content of an external communication, not its subjective effect on jurors. This protects the finality of verdicts and jury privacy while still allowing courts to address prejudicial outside influences through an objective 'reasonable possibility' standard.
