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liabilitystatuteappealtrialappellantjury instructions
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Mississippi Valley Silica Co., Inc. v. Eastman, 92 So.3d 666

Facts

Robert Eastman worked as a sandblaster for twenty-eight years, using silica sand supplied by MVS. He developed lung disease and silicosis, leading him to sue MVS under Mississippi's products liability statute, claiming the product was defective due to inadequate warnings. MVS argued that Eastman's employer, LeTourneau, was a sophisticated user and thus MVS had no duty to warn. The trial judge refused to give the sophisticated-user jury instruction, leading to MVS's appeal after the jury found it at fault.

For twenty-eight years, Robert Eastman worked as a sandblaster at LeTourneau, a shipbuilder in Vicksburg, Mississippi.

Issue

Did the trial court err in refusing to give the sophisticated-user jury instruction requested by MVS?

The issue we find dispositive is the trial judge's failure to instruct the jury on the sophisticated-user defense.

Rule

The trial judge has a duty to instruct the jury properly, including reforming any flawed jury instructions that relate to central issues in the case.

Our precedent on the issue was addressed succinctly in Byrd v. McGill, in which the trial judge refused to give a flawed jury instruction on the law of negligence per se.

Analysis

The court found that the trial judge abused his discretion by refusing to reform MVS's proposed sophisticated-user instruction. The instruction was relevant to the case, and the judge's failure to provide it deprived MVS of a fair trial. The court emphasized that the trial judge should have either corrected the instruction or provided a suitable definition to avoid confusion.

We find that the circuit judge abused his discretion by denying, rather than reforming, MVS' proposed “sophisticated-user” instruction.

Conclusion

The Supreme Court reversed the trial court's judgment and remanded the case for a new trial, emphasizing the importance of proper jury instructions.

Because we reverse and remand for a new trial, we decline to address the remaining issues.

Who won?

The prevailing party is the appellant, Mississippi Valley Silica Company, as the Supreme Court reversed the trial court's decision in their favor.

The Supreme Court, Dickinson, P.J., held that trial court had duty to reform proffered but incorrectly worded “sophisticated user” instruction.

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