Adams v. Toyota Motor Corp.
| Decision Date | 09 June 2017 |
| Docket Number | No. 15-2635, No. 15-2637,No. 15-2507, No. 15-2636, No. 15-2638, No. 15-2516,15-2507 |
| Parties | Jassmine D. ADAMS, Plaintiff-Appellee State of Minnesota, Department of Human Services; UCare Minnesota; Medica Health Plans, Intervenor Plaintiffs-Appellees v. TOYOTA MOTOR CORPORATION; Toyota Motor Sales, U.S.A., Inc.; Toyota Motor North America, Inc.; Toyota Motor Engineering and Manufacturing North America, Inc.; Toyota Motor Manufacturing, Kentucky, Inc.; Calty Design Research, Inc., Defendants-Appellants Quincy Ray Adams, Plaintiff-Appellee State of Minnesota, Department of Human Services; UCare Minnesota; Medica Health Plans, Intervenor Plaintiffs-Appellees v. Toyota Motor Corporation; Toyota Motor Sales, U.S.A., Inc.; Toyota Motor North America, Inc.; Toyota Motor Engineering and Manufacturing North America, Inc.; Toyota Motor Manufacturing, Kentucky, Inc.; Calty Design Research, Inc., Defendants-Appellants Jassmine D. Adams, Plaintiff-Appellant State of Minnesota, Department of Human Services; UCare Minnesota; Medica Health Plans, Intervenor Plaintiffs v. Toyota Motor Corporation; Toyota Motor Sales, U.S.A., Inc.; Toyota Motor North America, Inc.; Toyota Motor Engineering and Manufacturing North America, Inc.; Toyota Motor Manufacturing, Kentucky, Inc.; Calty Design Research, Inc., Defendants-Appellees Bridgette Trice, as trustee for the heirs and next of kin of Devyn Bolton, deceased, Plaintiff-Appellant Koua Fong Lee; Nhia Koua Lee; Nong Lee; Panghoua Moua; Jemee Lee, a minor child; American Family Mutual Insurance Company, as subrogee of Koua Fong Lee; State of Minnesota, Department of Human Services; UCare Minnesota; Medica Health Plans, Intervenor Plaintiffs v. Toyota Motor Corporation; Toyota Motor Sales, U.S.A., Inc.; Toyota Motor North America, Inc.; Toyota Motor Engineering and Manufacturing North America, Inc.; Toyota Motor Manufacturing, Kentucky, Inc.; Calty Design Research, Inc., Defendants-Appellees Bridgette Trice, as trustee for the heirs and next of kin of Devyn Bolton, deceased, Plaintiff Koua Fong Lee; Nhia Koua Lee; Nong Lee; Panghoua Moua; Jemee Lee, a minor child, Intervenor Plaintiffs-Appellants American Family Mutual Insurance Company, as subrogee of Koua Fong Lee; State of Minnesota, Department of Human Services; UCare Minnesota; Medica Health Plans, Intervenor Plaintiffs v. Toyota Motor Corporation; Toyota Motor Sales, U.S.A., Inc.; Toyota Motor North America, Inc.; Toyota Motor Engineering and Manufacturing North America, Inc.; Toyota Motor Manufacturing, Kentucky, Inc.; Calty Design Research, Inc., Defendants-Appellees Quincy Ray Adams, Plaintiff-Appellant State of Minnesota, Department of Human Services; UCare Minnesota; Medica Health Plans, Intervenor Plaintiffs v. Toyota Motor Corporation; Toyota Motor Sales, U.S.A., Inc.; Toyota Motor North America, Inc.; Toyota Motor Engineering and Manufacturing North America, Inc.; Toyota Motor Manufacturing, Kentucky, Inc.; Calty Design Research, Inc., Defendants-Appellees |
| Court | U.S. Court of Appeals — Eighth Circuit |
On June 10, 2006, Koua Fong Lee was driving his 1996 Toyota Camry on the interstate. When Lee exited the interstate, the Camry failed to come to a stop and rear-ended another car waiting at a stoplight, killing three of the other car's five passengers and injuring others, including those in Lee's vehicle. Lee was convicted of vehicular homicide, but his conviction was vacated after Toyota recalled several models of their Camry for issues related to unintended acceleration, ultimately leading to new evidence in Lee's case.
Family members of the deceased filed a lawsuit against Toyota in state court in 2010, alleging, among other things, personal injury and wrongful death based on strict product liability, and Lee eventually joined as a plaintiff. Following a four-week trial, a jury found Lee 40 percent and Toyota 60 percent at fault for the collision. The district court entered judgment on June 25, 2015. Having jurisdiction under 28 U.S.C. § 1291, we affirm in part and reverse in part.
In June 2006, after attending several family events in Minneapolis, Lee was driving his 1996 Toyota Camry eastbound on the interstate from Minneapolis toward St. Paul with his pregnant wife, their young daughter, his father, and his brother. He was going around 65 miles per hour. He exited the interstate at the Snelling Avenue ramp, which had a slight incline leading up to an intersection. Lee testified that he pressed on the accelerator as he went up the ramp and pushed on the brake at the top of the incline, approximately 600 feet from the intersection.
Lee and his passengers explained that as Lee approached the intersection, he pumped the brakes and yelled that they were not working. The Camry was going approximately 75 miles per hour when it rear-ended an Oldsmobile Ciera that was waiting at a red light, pushing the Oldsmobile into oncoming traffic. The Oldsmobile's driver, Javis Trice-Adams, and Trice-Adams' six-year-old son, Javis Jr., died at the scene of the collision. Quincy Adams, Trice-Adams' father, was seated in the front passenger seat and suffered a traumatic brain injury. Trice-Adams' niece, six-year-old Devyn Bolton, was seated in the middle of the back seat. Upon impact, she ceased breathing and her heart stopped beating. Paramedics revived her in the ambulance, though she stayed in a coma for a period of weeks. Devyn was rendered quadriplegic, and though she was able to fully regain her mental faculties, she died from respiratory complications arising from her quadriplegia approximately a year after the accident. Finally, Jassmine Adams, Trice-Adams' thirteen-year-old daughter, was seated in the back passenger seat of the car. Her leg was crushed by the impact, but she survived. Occupants of Lee's car were also injured, but all survived. In 2007, Lee was charged with vehicular homicide. Though he alleged at trial that the Camry's brakes were not working, he was convicted and sentenced to eight years in prison.
In 2010, Toyota recalled several models of their Camry — not including the 1996 Camry Lee was driving at the time of the accident — for issues related to unintended acceleration.1 Lee filed a petition for post-conviction relief in state court based on new information about instances of unintended acceleration in 1995 and 1996 Camrys, and his conviction was ultimately vacated. Prosecutors did not appeal or pursue additional criminal charges, and Lee was released after being incarcerated for over two years.
Family members of the deceased filed this product liability lawsuit against Toyota in state court in 2010, alleging that a defect in Lee's Camry's acceleration system led to the collision and resultant injuries. Lee eventually joined as a plaintiff. Toyota removed the case to federal court. Prior to trial, the district court ruled on a number of motions, including Toyota's motion to exclude evidence of other similar instances of unintended acceleration (OSIs) and Toyota's motion to exclude the testimony of the plaintiffs' mechanical engineering expert, John Stilson.2 The court allowed the plaintiffs to present OSI evidence, but required the plaintiffs to reduce their proposed witnesses to "a list of a much smaller number ... whose testimony is most similar," ultimately limiting the plaintiffs to three OSI witnesses. Each OSI witness testified that he was driving a 1996 Toyota Camry with over 100,000 miles on it when he experienced at least one incident of unintended acceleration.
The court denied the motion to exclude the plaintiffs' expert. At trial, the plaintiffs' expert, Stilson, explained the relevant parts of a 1996 Camry's engine, focusing specifically on the components of the accelerator control system — which included the throttle — and the cruise control system. Though both systems were housed within the same plastic dust cover, Stilson testified that the cruise control system was mechanically separate from the accelerator control system. Stilson opined that the accelerator control system was defective. He conducted testing which revealed that, when heated to a certain temperature, two of the throttle pulleys in the accelerator control system would bind together and cause the throttle to stick. In order to conduct these tests, he explained, he had to clip the cruise control arm away from its original factory position. Stilson ultimately concluded that the plastic dust cover had gaps allowing heat to enter and become trapped inside, causing the plastic throttle pulleys to overheat and stick together. In Stilson's opinion, this sticking defect led to the unintended acceleration, and ultimately to the collision in this case.
Prior to the verdict, Toyota moved for judgment as a matter of law (JAML), arguing that the evidence was insufficient to prove a design defect and causation. Toyota also reiterated its arguments about the inadmissibility of the OSI evidence and Stilson's testimony in post-trial motions, which the district court denied. The jury returned a $14 million verdict in favor of the plaintiffs, though the court reduced the monetary award to plaintiff Bridgette Trice, Devyn Bolton's mother, based on a prior settlement. Judgment was entered in June 2015. Toyota timely appealed and Trice cross-appealed.
On appeal, Toyota argues that the district court erred in (1) admitting the OSI evidence, (2) admitting Stilson's expert testimony, (3) denying Toyota's motion for JAML, and (4) awarding plaintiff Trice prejudgment interest. On cross-appeal, Trice argues that the district court erred in reducing her monetary award.
Toyota argues that the district court erred by allowing the plaintiffs to present evidence of allegedly similar incidents experienced by other 1996 Toyota Camry drivers. "The decision whether to admit `similar-incident' evidence is committed to the sound discretion of the district court," Arabian Agri....
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...a 30% chance is insufficient to trigger liability. This is dispositive of Plaintiffs' lost-chance arguments. See Adams v. Toyota Motor Corp. , 859 F.3d 499, 515 (8th Cir. 2017) ("[W]e must try to predict ‘how the state's highest court would rule if faced with the same question.’ " (quoting ......