DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
152507P.pdf 08/11/2017 Jassmine D. Adams v. Toyota Motor Corporation
U.S. Court of Appeals Case No: 15-2507
and No: 15-2511
and No: 15-2516
and No: 15-2635
and No: 15-2636
and No: 15-2637
and No: 15-2638
U.S. District Court for the District of Minnesota - Minneapolis
[PUBLISHED] [Kelly, Author, with Loken and Murphy, Circuit Judges]
Civil case - Products liability. In products liability claiming plaintiffs
were injured through unintended acceleration of plaintiff Lee's Toyota
Camry, the jury found Lee was 40% responsible for the collision and
assessed Toyota's fault at 60%. The district court did not abuse its
discretion in admitting evidence of "other similar incidents" of
unintended acceleration as the circumstances surrounding each incident and
this incident were similar in several important respects, and the district
court, which expressed a keen awareness of the problems associated with
such evidence, was in the best position to determine whether this evidence
would be unduly distracting to the jurors; the district court did not
abuse its discretion in admitting testimony by plaintiff's expert, a
mechanical engineer and experienced product designer for other auto
manufacturers; plaintiffs presented sufficient evidence from which a jury
could find that the 1996 Camry contained a design defect in its throttle
mechanism and that his defect was a substantial factor in creating the
harm; the jury heard evidence from both sides' experts regarding the cause
of the accident, and while Toyota disagrees with plaintiff's version of
the cause, questions of conflicting evidence must be left to the jury's
determination, and this court will not reweigh the evidence; the district
court erred in granting prejudgment pursuant to Minn. Stat. Ann. Section
549.09 on plaintiff Bridgette Trice's damage award; on Trice's
cross-appeal, the district court erred in offsetting her damage award to
account for a prior settlement she entered into with plaintiff Lee and his
insurer as she received those damages as guardian on behalf of her minor
daughter who was injured in the accident and was still living at the time
of the settlement; her damage award here was received as the wrongful
death trustee and personal representative of a decedent's next of kin;
allowing the deceased child's next of kin to recover the full amount of
the jury award is not inequitable because the child recovered for her own
injuries while she was living.
152507P.pdf 06/09/2017 Jassmine D. Adams v. Toyota Motor Corporation
U.S. Court of Appeals Case No: 15-2507
and No: 15-2511
and No: 15-2636
and No: 15-2637
and No: 15-2516
and No: 15-2638
and No: 15-2635
U.S. District Court for the District of Minnesota - Minneapolis
[PUBLISHED] [Kelly, Author, with Loken and Murphy, Circuit Judges]
Civil case - Products Liability. In action involving unintended
acceleration in Toyota Camrys, the district court carefully weighed the
admission of other similar incident evidence and did not abuse its
discretion in admitting a limited number of substantially similar
incidents; argument that the district court erred in allowing plaintiffs'
expert to give his opinion regarding the cause of the unintended
acceleration rejected as this testing supported his theory of the defect
and the evidence he relied on was sufficient to support the theory;
plaintiffs presented sufficient evidence from which a jury could find that
the 1996 Camry contained a design defect which was the proximate cause of
the accidents at issue; taking into account the plain language of Minn.
Stat. Ann. Section 549.09 regarding prejudgment interest, lower state
court decisions and the purpose of the statute, the court predicts that
the Minnesota Supreme Court would conclude that prejudgment interest is
not available for judgments that encompass multiple types of interest -
some of which are subject to interest under the statute and some of which
are not - when it is impossible to differentiate between the types of
damages included in the judgment, and the district court erred in awarding
prejudgment interest; with respect to plaintiff Trice's cross-appeal, the
district court erred in reducing her wrongful death damages award by the
amount her decedent recovered from the driver of the other vehicle and his
insurers.