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Keywords

appealtrialcompliance
trialcompliance

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Schultz v. Ford Motor Co., 857 N.E.2d 977, Prod.Liab.Rep. (CCH) P 17,623

Facts

In December 1997, Richard Schultz lost control of his 1995 Ford Explorer on black ice, leading to a rollover accident that caused the roof to collapse and injure him severely. Schultz and his wife sued Ford Motor Company, claiming the vehicle's roof design was defective and that Ford was negligent. The jury found in favor of Ford, leading to an appeal by the Schultzes, who argued that the jury was improperly instructed regarding the presumption of compliance with federal safety standards.

In December, 1997, Richard Schultz lost control of his 1995 Ford Explorer when it hit a patch of black ice on Indiana State Road 2.

Issue

Did the trial court err in giving the jury instruction regarding the presumption of compliance with federal safety standards, and did this instruction violate Indiana Evidence Rule 301?

Did the trial court err in giving the jury instruction regarding the presumption of compliance with federal safety standards, and did this instruction violate Indiana Evidence Rule 301?

Rule

Indiana Evidence Rule 301 allows for a presumption to have continuing effect even when contrary evidence is presented, and it governs the instructions given to juries regarding presumptions.

A presumption shall have continuing effect even though contrary evidence is received.

Analysis

The Supreme Court of Indiana analyzed the jury instruction in light of Indiana Evidence Rule 301, determining that the instruction properly allowed the jury to infer the existence of a presumed fact when a basic fact was proven. The court noted that while the use of the terms 'presume' and 'presumption' could be seen as problematic, they did not constitute reversible error in this case. The instruction was deemed fair to both parties, as it allowed the jury to consider evidence presented by the Schultzes to rebut the presumption.

We think a typical juror would find it to have been synonymous with 'infer' or, perhaps, 'assume,' the word Weinstein suggests be used in such circumstances.

Conclusion

The Supreme Court affirmed the trial court's judgment, concluding that the jury instruction regarding the presumption was appropriate and did not constitute reversible error.

The judgment of the trial court is affirmed.

Who won?

Ford Motor Company prevailed in the case because the Supreme Court found that the jury instruction regarding the presumption of compliance with safety standards was appropriate and did not mislead the jury.

Ford Motor Company prevailed in the case because the Supreme Court found that the jury instruction regarding the presumption of compliance with safety standards was appropriate and did not mislead the jury.

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