Yes, the judge was wrong to overrule the jury. The jury had good reason to believe the lawn mower was unsafe and caused the injury. Norton's experts showed that a better safety device existed back then that could have stopped the blades in under a second. The jury was allowed to believe Norton's experts over the company's experts. Also, it was logical for the jury to conclude that this defect caused the injury. Since the mower slid for a few seconds, the extra time the blades were spinning was likely when Norton's hand got caught. This wasn't just a wild guess; it was a reasonable conclusion based on the facts.

The judge shouldn't have overruled the jury because there was enough evidence to reasonably conclude that the 1981 Snapper mower was defective without a good emergency blade-stop feature and that this flaw caused Norton's injuries.

Experts testified that effective safety devices that could stop mower blades in under a second were possible to install in 1981. Snapper even applied for a patent on one in 1980. Snapper said Norton couldn't prove the safety device would have prevented his injuries, but the jury had enough clues to infer that a better blade-stop feature would have kicked in during the seconds the mower slid backwards, likely preventing or reducing Norton's injuries.

The jury appropriately weighed things like consumer expectations and the balance between the mower's risks and benefits in deciding it was unreasonably dangerous without the safety device. Their decision had substantial evidence behind it, so the judge was wrong to overrule it. The judge's ruling is reversed, and the court is instructed to enter a judgment in favor of Norton.

—was right on point in its decision to reverse the lower court's judgment notwithstanding the verdict because expert opinions were offered that "state of the art" deadman devices were available, but Snapper instead decided to pursue their own form of dead man device.

After noting that "the use of `state of the art'evidence infuses some measure of `fault'analysis into the strict liability equation, "the Eleventh Circuit concluded that" the ability to eliminate or minimize the danger without seriously impairing the product or making it unduly expensive "is a factor in determining whether a product is unreasonably dangerous.

Several federal courts sitting in diversity have suggested that Florida also recognizes a consumer expectations test, relying primarily on Florida standard jury instructions.

This procedure permits the court to submit the case to the jury, then grant the motion after the verdict is returned.

—the issue was whether the failure to install a "dead man" device rendered a Snapper mower unreasonably dangerous.

In contrast, courts applying the Cassisi version of the risk-utility test identify the availability of an alternative design as merely one of the factors to consider in the analysis.

For a case holding that a judgment nov could be granted sua sponte, and the court need not expressly reserve its ruling on a previous motion for a directed verdict

Vaughan & Bushnell care in use of the product (including the effect of instructions or warnings), and (7) the ability to eliminate the danger without seriously impairing the usefulness of the product or making it unduly expensive.

Thus, an unsafe product, whether it be characterized as inherently dangerous or unavoidably dangerous, would not necessarily be an unreasonably dangerous product.

A jury could find that a riding lawn mower is defective if the machine lacks an OPC to stop the blade should the operator lose control or disembark with the blade engaged.

Yes. The district court erred because there was substantial evidence to support the jury's verdict. A court may only grant a judgment notwithstanding the verdict (JNOV) when the evidence so strongly favors one party that reasonable people could not arrive at a contrary verdict. In this case, Norton presented sufficient evidence on both defect and causation. Regarding the defect, Norton's expert testified that the technology for a 'dead man' device capable of stopping the blades in under one second existed well before 1981, rendering the mower 'unreasonably dangerous' without it. Although Snapper presented conflicting expert testimony creating a 'state of the art' defense, it was the jury's role to weigh this conflicting evidence. Regarding causation, the evidence, though circumstantial, supported a reasonable inference that the defect caused the injury. Given Norton’s testimony that he slid for six feet with his hands on the handlebars until impact, and expert testimony that this slide would take several seconds, the jury could reasonably infer that the 2-3 second difference in blade-stopping time between the existing design and a feasible safer design was the cause of his injury. This was a permissible 'inference upon an inference,' not mere speculation.

The district court erred in granting the judgment notwithstanding the verdict because the evidence presented at trial allowed for a reasonable inference that the lack of an effective dead man control on the 1981 Snapper mower rendered it defective and that this defect caused Norton's injuries. 

Expert testimony indicated that state-of-the-art dead man devices capable of stopping mower blades in under one second were feasible in 1981. Snapper's own patent application from 1980 further supported this. While Snapper argued that Norton failed to prove causation, the circumstantial evidence was sufficient for the jury to reasonably infer that a more effective dead man control would have engaged during the several seconds the mower slid backwards, preventing or reducing the severity of Norton's injuries. 

The jury properly considered factors such as consumer expectations and the risk-utility balance in determining the mower was unreasonably dangerous without the safety device. Their verdict was supported by substantial evidence, so judgment as a matter of law for Snapper was improper. The judgment is reversed with instructions to enter judgment for Norton.

Norton v. Snapper Power Equipment

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