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Keywords

plaintiffliabilityappealtrialverdicttestimonycorporationjury instructions
appealtrialverdictmotion

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Vaughn v. Nissan Motor Corp. in U.S.A., Inc., 77 F.3d 736, Prod.Liab.Rep. (CCH) P 14,525

Facts

Donna Vaughn was driving her 1989 Nissan Pulsar when the voltage regulator failed, causing toxic fumes to enter the passenger compartment. Vaughn inhaled these fumes, resulting in vocal chord dysfunction and reactive airway dysfunction syndrome (RADS). Two experts testified that the voltage regulator was defectively designed, while Nissan's expert argued that the fumes did not enter the car in harmful concentrations. The district court excluded testimony from Vaughn's physicians regarding the cause of her vocal chord dysfunction, and the jury ultimately ruled in favor of Nissan.

On May 5, 1991, Donna Vaughn was driving her 1989 Nissan Pulsar on Interstate 95 in Colleton County, South Carolina. The voltage regulator failed, which in turn caused excessive current, which in turn caused the battery fluid to boil.

Issue

Did the district court err in instructing the jury that Vaughn could only recover if she was an 'ordinary consumer'?

The jury returned a verdict for Nissan. Vaughn's motion for a new trial was denied, and she appeals.

Rule

In products liability cases, a product is considered unreasonably dangerous if it poses a risk to the ordinary consumer for whom it is designed, and recovery is not limited to ordinary consumers alone.

The 'defect' must cause the product to be unreasonably dangerous. A car with a bad radio is not unreasonably dangerous; a car with bad brakes may be.

Analysis

The court determined that the jury instruction was erroneous because it improperly restricted recovery based on the plaintiff's status as an 'ordinary consumer.' The court emphasized that the determination of whether a product is unreasonably dangerous should not depend on the plaintiff's characteristics but rather on the product itself. The erroneous instruction likely influenced the jury's verdict, as it could have led them to believe that Vaughn's psychological issues barred her from recovery.

This faulty instruction requires reversal. It could very, very easily explain the verdict, because the evidence on this point was perhaps the most clear-cut in Nissan's favor of any issue that went to the jury.

Conclusion

The Court of Appeals vacated the judgment of the district court and remanded the case for a new trial due to the reversible error in jury instructions.

The judgment of the district court is vacated, and the case is remanded for a new trial.

Who won?

Nissan Motor Corporation prevailed in the initial trial due to a jury verdict, but the appellate court's decision to vacate the judgment means that Nissan's victory is not final.

Nissan took full advantage of the error in final argument, emphasizing that Vaughn has severe psychological problems and that those problems bar recovery.

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