Sawyer v. Dreis & Krump Manufacturing Co.
67 N.Y.2d 328, 493 N.E.2d 920, 502 N.Y.S.2d 696 (1986)
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Rule of Law:
A plaintiff claiming amnesia resulting from a defendant's acts must present expert medical evidence to prove the amnesia and its causal link to the accident by clear and convincing evidence before being entitled to a lesser degree of proof in establishing their claim.
Facts:
- Plaintiff, an operator with five years of experience on press brakes, was injured when his hand was crushed in a press brake manufactured by Dreis & Krump Manufacturing Company.
- The press brake is a mechanical device that bends sheet metal; it operates when a foot pedal is depressed, causing a ram to descend 14 inches to the bed to shape metal.
- Proper set-up procedure for the press brake requires inserting dies, inching the ram close to the bed, inserting a scrap piece of metal, and then setting L-shaped stops at the back of the bed to hold the metal in position.
- Plaintiff stated at trial that he could not remember how the accident happened but believed he was injured when he reflexively reached under the ram to secure a piece of slipping sheet metal and accidentally stepped on the foot pedal.
- Plaintiff had previously testified that he set the stops by eye without a piece of scrap metal, contradicting his trial testimony that he set them against scrap metal.
- Plaintiff's foreman heard metal fall, and after the accident, saw metal hanging from the press and plaintiff's hand trapped, at which point plaintiff stated, "I finally done it."
- Dreis & Krump Manufacturing Company contended plaintiff was injured because his hands, holding the metal as required, were pulled under the ram due to his improper securing of the metal on the bed.
Procedural Posture:
- Plaintiff brought an action against Dreis & Krump Manufacturing Company in a trial court (court of first instance) seeking to recover for injuries.
- Defendant Dreis & Krump Manufacturing Company impleaded plaintiff’s employer, Cambridge Filter Corporation, as a third-party defendant.
- The case was submitted to a jury on theories of negligence and products liability.
- The jury found no fault on plaintiff’s part and awarded him a substantial verdict, apportioned equally between defendant Dreis & Krump Manufacturing Company and third-party defendant Cambridge Filter Corporation.
- The Appellate Division (intermediate appellate court) affirmed the judgment.
- The New York Court of Appeals (highest court) granted leave to appeal.
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Issue:
Does a plaintiff claiming amnesia resulting from a defendant's acts need to introduce expert medical testimony to prove the amnesia and its causal relationship to the accident before a jury can be instructed to apply a lesser degree of proof in evaluating the claim?
Opinions:
Majority - Simons, J.
No, a plaintiff claiming amnesia resulting from a defendant's acts must introduce expert medical testimony to prove the amnesia and its causal relationship to the accident before a jury can be instructed to apply a lesser degree of proof in evaluating the claim. The court reasoned that amnesia, as a medical condition, is beyond the understanding of laymen, making expert evidence not only helpful but required to establish the condition and its causal link to the defendant's actions by clear and convincing evidence. Without expert aid, a jury cannot properly evaluate the effects of trauma or verify the loss of memory, which can be easily feigned. The court also found reversible error in permitting plaintiff's engineering expert to speculate on the accident's cause without proper factual foundation, in allowing cross-examination about other accidents without establishing their similarity, and in failing to properly instruct the jury that industry safety standards (ANSI) were merely 'some evidence' of negligence and not conclusive. These errors substantially prejudiced the defendant and necessitated a new trial.
Analysis:
This case significantly clarifies the evidentiary requirements for plaintiffs seeking the benefit of a lesser burden of proof due to amnesia, mandating expert medical testimony to substantiate the claim. It reinforces the principle that expert testimony must be based on established facts, not speculation, and reiterates the strict standard for admitting evidence of prior accidents, requiring substantial similarity. Furthermore, the decision emphasizes that industry safety standards are advisory and not determinative of negligence, requiring proper jury instructions. These rulings collectively ensure a more rigorous standard of proof in specific evidentiary contexts, promoting fairness and preventing speculation in jury deliberations, thereby impacting future products liability and negligence cases involving memory loss or industry standards.
