Wilson v. Vermont Castings
977 F. Supp. 691 (1997)
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Rule of Law:
Under Federal Rule of Evidence 606(b), a juror bringing extraneous information into deliberations does not warrant a new trial unless the information was prejudicial to the moving party, which is determined by an objective test of whether it would affect a typical juror on the issue decided against that party.
Facts:
- Anne Wilson owned a woodburning stove sold by Vermont Castings, Inc.
- On November 16, 1991, Wilson's clothing caught fire while she was attempting to light a fire in the stove.
- As a result of her clothing catching fire, Wilson suffered severe burns.
- Wilson's theory of liability was that the stove was defectively designed because it required users to leave the door slightly ajar to start a fire, and it lacked a warning on the stove itself about this danger.
- Wilson testified during litigation that she had never read the instruction manual that accompanied the stove.
Procedural Posture:
- Anne Wilson and Oliver J. Larmi filed a diversity action against Vermont Castings, Inc. in federal district court, alleging strict liability and negligence.
- The case proceeded to trial on a strict liability theory only.
- A jury returned a verdict in favor of the defendant, Vermont Castings.
- On a special verdict form, the jury found that the stove was defective, but that the defect was not a substantial factor in causing Wilson's injury.
- Plaintiffs filed a motion for a new trial, alleging juror misconduct and other trial errors.
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Issue:
Does a juror's consultation of an external instruction manual for a product at issue in a trial, and sharing that information with other jurors, constitute extraneous prejudicial information warranting a new trial under Federal Rule of Evidence 606(b) when the jury found in the moving party's favor on the only issue to which that information was relevant?
Opinions:
Majority - McClure, District Judge.
No. While a juror's independent review of an instruction manual not in evidence constitutes extraneous information, it does not warrant a new trial if it is not prejudicial to the losing party. The court distinguished between a juror's general life experience, which is permissible to share, and an external investigation, which is improper. Here, the juror's consultation of her own stove manual was extraneous. However, for a new trial to be granted, the extraneous information must have been prejudicial. The court applies an objective test, assessing whether the information would affect a 'typical juror.' The information from the manual was only relevant to the issue of whether the stove was defective. The jury found in favor of the plaintiffs on that specific issue, determining the stove was, in fact, defective. The plaintiffs lost on the separate issue of causation—whether the defect was a substantial factor in causing the injury. Because the extraneous information had no bearing on the issue of causation, the plaintiffs suffered no prejudice, and therefore, a new trial is not justified.
Analysis:
This memorandum opinion provides a clear application of Federal Rule of Evidence 606(b), differentiating between a juror's permissible use of life experience and impermissible introduction of extraneous information. The case establishes that the mere presence of extraneous information is insufficient to overturn a verdict; the critical inquiry is whether that information was prejudicial to the moving party. By linking the prejudicial effect directly to the specific jury finding against the movant, the court sets a high bar for challenging verdicts on grounds of juror misconduct, reinforcing the finality of jury decisions unless a clear, harmful error is demonstrated.
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