Wilson v. Vermont Castings, Inc.
170 F.3d 391 (1999)
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Rule of Law:
A new trial is not warranted due to a juror's introduction of extraneous information unless that information was prejudicial to the moving party, which is determined by an objective assessment of its effect on a hypothetical average juror, not by inquiring into its subjective effect on the actual jurors.
Facts:
- Anne Wilson owned a woodburning stove manufactured by Vermont Castings.
- On November 16, 1991, while operating the stove, Wilson left a side door open to help the fire start.
- As she stood near the stove to warm herself, her dress caught on fire.
- Wilson sustained serious burns and the loss of her fingers on her left hand.
Procedural Posture:
- Anne K. Wilson sued Vermont Castings, Inc. in the U.S. District Court for the Middle District of Pennsylvania for strict products liability.
- Prior to trial, the district court granted Vermont Castings's motion to exclude evidence of the stove's owner's manual because Wilson had never read it.
- Following a thirteen-day trial, the jury returned a verdict for Vermont Castings, finding the stove was defective but that the defect was not a substantial factor in causing Wilson's injuries.
- Post-trial, Wilson learned of potential juror misconduct and filed a motion for a new trial, alleging juror exposure to extraneous information and improper arguments by the defendant.
- The district court denied Wilson's motion for a new trial.
- Wilson (appellant) appealed the denial of her motion to the U.S. Court of Appeals for the Third Circuit, with Vermont Castings as the appellee.
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Issue:
Does a juror's introduction of extraneous information, specifically the contents of a product's owner's manual, warrant a new trial when that information is relevant only to an issue on which the moving party prevailed?
Opinions:
Majority - Magill, Senior Circuit Judge
No, a juror's introduction of extraneous information does not warrant a new trial when the information is relevant only to an issue on which the moving party prevailed. Federal Rule of Evidence 606(b) permits a court to inquire into whether extraneous prejudicial information was brought to the jury's attention, but prohibits inquiry into the subjective effect of that information on any juror. The court must make an objective assessment of how the information would affect a hypothetical average juror. Here, the extraneous information from the owner's manual concerned warnings, which is relevant only to the issue of whether the stove was defective. Because the jury found the stove was defective, Wilson prevailed on this issue and therefore could not have been prejudiced by the information. The juror's personal opinion on her own future conduct was part of her subjective deliberative process and life experience, which is not considered extraneous information subject to inquiry.
Analysis:
This decision reinforces the high threshold required to overturn a jury verdict based on juror misconduct, strictly applying Federal Rule of Evidence 606(b). It clarifies the critical distinction between impermissible 'extraneous information' and a juror's permissible application of their own experiences and subjective reasoning, which are shielded from judicial inquiry. The ruling demonstrates that the prejudice analysis is not abstract; the extraneous information must have been capable of harming the moving party on an issue they actually lost. The case also serves as a strong reminder of the 'contemporaneous objection rule,' emphasizing that a party's failure to object to perceived errors at trial results in a waiver of those issues on appeal.
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