Patterson v. Central Mills, Inc.
64 F. App'x 457 (2003)
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Rule of Law:
The public records exception to the hearsay rule under Federal Rule of Evidence 803(8)(C) applies to the official findings and opinions of a government agency itself, but not to the personal opinions of individual members contained within the agency's reports.
Facts:
- In the fall of 1996, Beatrice Patterson purchased a 'Tasmanian Devil' t-shirt, made of a 50/50 cotton-polyester blend, for her ten-year-old son, Maurice Patterson.
- The shirt was an adult size, purchased from a Meijer store, and had been screen-printed and distributed by Central Mills, Inc.
- On January 26, 1997, Maurice, while wearing the t-shirt, went to the kitchen to cook hot dogs.
- He turned on the right front burner of the gas stove.
- Maurice then climbed onto the kitchen counter to search for ketchup in the cabinets located above the stove.
- While leaning over the stove, the bottom of Maurice's shirt came into contact with the lit burner and caught fire.
- Maurice attempted to put the fire out with his hands and then ran to the sink, but the flames spread quickly.
- He suffered second and third-degree burns over 25 to 35 percent of his body.
Procedural Posture:
- Maurice and Beatrice Patterson sued Central Mills, Inc. and Meijer, Inc. in the Lucas County (Ohio) Court of Common Pleas, a state trial court.
- The defendants removed the case to the United States District Court for the Northern District of Ohio.
- Prior to trial, the district court granted defendants' motions in limine, excluding parts of a video depicting Maurice's therapy and prohibiting the Pattersons' expert from testifying about flammability warnings.
- An eight-day jury trial was held on the Pattersons' breach of warranty and products liability claims.
- The jury returned a verdict in favor of defendants Central Mills and Meijer.
- The district court denied a motion for a new trial filed by the Pattersons.
- The Pattersons, as appellants, appealed the judgment to the United States Court of Appeals for the Sixth Circuit.
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Issue:
Do a trial court's evidentiary rulings excluding expert testimony, portions of government reports, and certain exhibits, along with its jury instructions on the affirmative defenses of misuse and assumption of the risk, constitute an abuse of discretion or reversible error in a products liability case?
Opinions:
Majority - McKeague, District Judge
No, the trial court's evidentiary rulings and jury instructions did not constitute an abuse of discretion or reversible error. The district court acted within its discretion on all challenged rulings. The exclusion of flammability warning labels from children's sleepwear was proper because they were not relevant to an adult-sized t-shirt. The court correctly limited the plaintiffs' expert's testimony on warnings under Daubert, as the expert lacked specific knowledge, training, or experience regarding warnings on clothing. The court also properly excluded personal statements of individual commissioners from CPSC reports, as the public records exception to hearsay applies only to the agency's official findings, not the opinions of its individual members. Finally, the jury instructions on misuse and assumption of the risk were supported by the evidence, as a jury could find that Maurice's act of leaning over a lit burner was an unforeseeable misuse of the shirt and that he knew clothing could burn.
Analysis:
This decision reinforces the significant gatekeeping role and broad discretion afforded to trial courts in managing evidence, particularly concerning expert testimony under the Daubert standard and the application of hearsay exceptions. It clarifies a key limit on the public records exception (FRE 803(8)(C)), establishing that personal opinions within government reports are not admissible under this rule, only the agency's formal findings. The case also serves as a practical example of how a plaintiff's conduct, even a child's, can provide a sufficient evidentiary basis for a court to instruct a jury on affirmative defenses like product misuse and assumption of the risk in a products liability action.
