Jarvis v. Ford Motor Company (2002)
The current paper provides an analytical study of the Jarvis V. Ford Co. case whose verdict was made on the seventh of February in the year 2002. The case was first brought to court and subjected to a trial in New York. The trial court represented a District court in the southern district of New York. As a court of original jurisdiction examining various matters of this nature, it had the requisite jurisdiction to listen to and determine the suit.
An appeal was later lodged at the U.S. Court of Appeals of the second circuit in New York. The bench comprised Circuit Judges Oakes, Van Graafeiland, and Sotomayor. Kathleen Madaline Jarvis, who was the Plaintiff, was suing not only in her capacity but also as Paul Michel Attila Jarvis’ mother and guardian. The case analysis will be conducted by providing brief facts regarding the case, identifying the procedure applied by the Court, pointing out the issues under the Court’s consideration, assessing the Court’s reasoning for its determination, and eventually identifying the rules of the case. Jarvis V. Ford Motors Co. is a significant product liability case that highlights negligence and strict liability rules where manufactured products were found defective.
Plaintiff Jarvis filled out a suit against the Ford Company on product liability alleging that her 6-day-old 1991 Aerostar was defective. She was suing the defendant under the doctrine of defective designs where her Plaint heavily relied on negligence and strict liability theories. Jarvis’ case explained that as soon as she put the ignition on while placing her foot gently on the brake pad, the van took off very fast and the brakes refused to work no matter how much she tried pumping them. Before the trial commenced in the District Court, both Jarvis and the Ford Company requested the judge to guide the jury regarding the issues of negligence and strict liability. In response to the parties’ request, the judge sought clarification from them where the plaintiff had to withdraw the negligence claim regardless of whether it would be a duplicate of his strict liability claim. The Court referred to (Pahuta v Massey-Ferguson. Inc., 1999), where the concern was first raised.
The Court in this matter found that there were major similarities in the essentials of both liabilities, including the issues of negligence and strict liability. In response to the assumptions of the Court, Defendant expressed the opinion that the jury ought to be given instructions on one theory and not both. A consensus was reached where all parties agreed that the jury ought to be instructed on the issue of negligence and strict liability. The eventual verdict of the jury was that the Defendant was liable for negligence but not culpable under strict liability. Ford did not agree with the verdict, and as a result of which they appealed the case arguing that the verdict made by the jury was inconsistent. Ford’s move was granted by the District Court and the judgment was delivered as a matter of law. In making the judgment, the District Court held that Ford did not waive its objection to the jury instruction as stipulated in its letter to the court. Jarvis did not agree with this judgment and hence appealed.
The suit originated in N.Y. District Court where it was heard and discussed. The presiding judge was Justice Buchwald. A notable argument that arose in this court was whether Negligence and Strict Liability charges were inconsistent. By citing the Pahuta case, the Court sought to inquire whether the Plaintiff could fill out an application for the consideration of both charges. The jury’s verdict that was made regarding the Plaintiff was set aside by the District Court as a matter of law citing that the verdict was inconsistent, while the Court perceived Negligence and Strict Liability as the same thing.
Being unsatisfied with the judgment as a matter of law under the trial court, Jarvis applied for a review of the verdict in a second circuit of the U.S. Court of Appeal in New York. This Court’s bench comprised Circuit Judges Oakes, Van Graafeiland, and Sotomayor. At the Court of Appeal, the trial court decision was quashed and an order to reinstate the verdict of the jury was issued. In support of its decision, the Court argued that Ford had waived its claim of error as it did not specifically indicate the nature and the grounds of its objection before the final deliberations of the jury. The Court further argued that the jury’s verdict did not have a significant error that could give the Defendant the right to appeal.
Issues under Consideration
From Jarvis’ Appeal, the Court was to find solutions to the following issues:
- Validity of the Trial Court’s Judgement as a matter of law.
- Whether the District Court erred in finding that the Defendant/Respondent had not waived their objection based on an inconsistent verdict.
- Discretion of the trial court in reducing the jury’s award to the Plaintiff.
- Trial Court’s dismissal of the punitive damages claim.
Court Analysis or Reasoning for its Decision
- District Court Judgement as a matter of law.
By citing Fed.R.Civ.P 50(a), The Court of Appeal found that the judgment as a matter of law was applicable after a litigant’s case had been finalized on the respective issue and in case there was not enough legal evidence that could form a basis for the opposite which a reasonable jury could find for the Plaintiff or Defendant on that issue. The Court further interpreted Rule 50 to establish that, the court of the original jurisdiction had to look into the evidence provided in a manner that they did not treat prejudicially the party against whom the motion was made. The court should ensure that the other party is given all reasonable conclusions that the jury might deduce from the evidence. The motion of judgment as a matter of law restricts the Court from evaluating the magnitude of the inconsistent evidence, ignoring the integrity of the witness, or substituting its judgment for that of the jury. (Tolbert v. Queens College, 2001).
Concerning Ford’s motion as a matter of law, the Court of Appeal quashed the trial court’s decision arguing that there was enough evidence for the jury to make its determination. The Court argued the evidence provided by Jarvis who convinced the jury that her 1991 Aerostar accelerated abruptly and that the brake system was faulty. The evidence was based on her testimony, as well as the testimony of other eyewitnesses including Jarvis’ father, testimonies from other Aerostar owners who had encountered a similar ordeal, expert witness statements, and a record of about 560 persons who had previously complained to Ford Company of a similar defect.
Notwithstanding the Plaintiff’s proof of the specific fault or Defendant’s argument that the accident happened as a result of the driver’s incompetence, by citing (Codling v. Paglia, 1973) the court held that, Plaintiff was not under any legal obligation to prove the specific defect as long as it was proved that the van did not operate as normally intended. The Court’s decision was also informed by the liability principle created under the New York Law on defective designs. The rule stipulates that a plaintiff in a product liability action is not required to prove a particular defect if the defect can be seen from the mere fact that the product is not functioning normally as promised by the manufacturer. The Court held that the jury sufficed in claiming that the Defendant was negligent when she found that the cruise system was defective, and based on the presence of this defect, it was reasonable that the van was dangerous if put to its normal use, and Ford was aware of the defect long before selling the product but took no action to remedy the fault.
- The Defendant’s Inconsistence Verdict Motion.
Plaintiff invited the Court of Appeal to establish whether the District Court erred in allowing Defendant’s inconsistent motion and the subsequent judgment. Upon hearing the matter at the District Court, the jury made a verdict that the Defendant was negligent but did not find it culpable under the Strict Liability rules. According to the Defendant, the jury contradicted itself in its verdict by finding that the Defendant had designed the cruise control system without any defect and at the same time found that it was the defendant’s fault that caused the accident. The argument here was that, if the answer to the strict liability question on the Defendant’s guilt proved their innocence, then a similar answer must be given to the question of whether it was the Defendant’s action or negligence that caused the plaintiff’s injuries. The District Court found merit in the Plaintiff’s motion and eventually set aside the Jury’s verdict as a matter of law.
In criticizing the District Court’s judgment, the Court of Appeals argued that the lower Court ought to have considered issuing an appropriate relief instead of granting the Defendant’s motion for judgment as a matter of law with the argument that the Plaintiff’s evidence was insufficient. The Court of Appeals argued that the lower Court erred in law by finding that the Defendant had not waived its objection and because the Defendant had not indicated the grounds of its objection. In Fed.R.Civ.P.51, there is a strict requirement that any objection must stipulate the basis of the given object. The Court of Appeal ordered the reinstatement of the jury’s verdict as the Court did not find any fundamental error that could warrant the need to set the verdict aside.
- Granting of the Defendant’s motion to have the jury’s award reduced without a hearing.
Jarvis’ case on this issue was that the District Court had abused its discretion by allowing the Defendant’s motion to reduce her damages. Jarvis was arguing that there was no sufficient evidence of collateral source payments that she received in the past or will receive in the future. Availability of Collateral Source payments would fall under the same principle of the law of insurance which deprives an insured of double compensation. The defendant could legally assess whether there were other ways in which the Plaintiff could benefit by determining the number of damages to pay. The Court of Appeal in rejecting Jarvis’ contention argued that there was enough evidence that she was and will continue receiving current and long-term disability funds from her insurance policy and from the private disability organization that was at that time giving her monthly allowances.
- Plaintiff/Appellant’s claim for punitive damages
In defeating Jarvis’ claim, the Court of Appeal cited the counsel for the plaintiff’s oral argument where he stated that the Plaintiff would waive the proceedings on punitive damages if the jury’s verdict was reinstated and there was provided a fair determination of collateral sources. The waiver for punitive damages was conditional with two conditions that must be met first. The first ultimatum was met when the reviewing court directed the Trial Court to reinstate the jury’s decision. According to the Court of Appeal, the second condition was defeated as the Plaintiff only argued that there was no sufficient evidence to support the collateral source payments, an argument that the court dismissed. The reasoning of the Court was informed by the requirement of the Law of Evidence Rules which stipulates that material facts must be specifically pleaded. Jarvis ought to have pleaded on the issue of collateral source payments other than merely arguing that there was insufficient evidence. Such a claim would be completely defeated if the evidence was availed as it was in this case.
The Rule or Court of Appeals’ Holding
The judgment, in this case, was not entered unanimously but it was the judgment of the majority with one judge dissenting. The following were the determinations of the majority.
The reviewing court was satisfied that Jarvis’1991 Aerostar’s cruise control system was faulty and upheld the jury’s findings on negligence hence proving the need for the award for damages.
The Court further held that by failing to specifically object to the verdict, Defendant/Respondent had waived any of its objections to an inconsistent verdict.
The Court upheld the District Court’s reduction of the jury award by N.Y.C.P.L.R 4545(c).
The Court vacated the District Court’s judgment and gave instructions for the judgment to be entered in the Plaintiff’s favor by their opinion on the matter.
Whether the Court’s Decision was Fair.
Having analyzed in depth the judgment and reasoning of the majority and the dissenting opinion of the judge, I think that the Court of Appeal ought to have ordered a re-trial.
- Inconsistent Verdict
One of the contentious issues that Defendant raised as a ground for its objection to the jury verdict was related to inconsistency. Defendant argued that there was no way that the Jury could find that it had designed the cruise control system properly and that it was fit for the intended use, and at the same time it could not argue that Defendant was negligent as it sold the van knowing that the cruise control system had defects that could endanger the user when the van was subjected to its normal use.
The majority decided that the Defendant’s objection could not hold water since it did not indicate the fundamental error in the verdict. Earlier when both parties were asked by the Trial Court whether they would want the Jury to be instructed on both strict liability and negligence, Ford indicated clearly that it wanted either of the two but not both liabilities charged as in its opinion they were the same thing. An inference could therefore be made meaning that the fundamental error that Ford saw in the verdict was the jury’s treatment of both liabilities as though they were different and unrelated.
In (Denny v Ford Motor Co.,1995), the court proclaimed that claims connected with such issues as negligence and strict liability for the product’s defect are almost impossible to prove and differentiate. Elsewhere in (Barry v. Manglass,1981), the Court of Appeal held that a verdict is inconsistent if a determination on one of the claims disregards the elements of the other cause of action. In this case, when deciding that Defendant was negligent and had no blemish under strict liability, the jury failed to put into consideration the elements of the strict liability rule. In (Robinson v. Reed-Prentice Div. of Package Mach. Co., 1980), the Court held that strict liability on products occurs when a manufacturer sells a product that has a defect that causes injury.
Concerning the issue of Negligence, the New York District Court’s theory on faulty goods stipulates that a manufacturer is liable for negligence if the plaintiff shows that it was the manufacturer’s fault that caused the defect and that the injury was foreseeable. Citing these pieces of authority, it is clear that there was no way that the jury could find a fault in one and no fault in the other. If the cruise control system was not knowingly placed for sale in the market with defect by the manufacturer, then there is no way that the manufacturer could have been negligent in designing the cruise control system and there is also no way that the accident could be the manufacturer’s fault but rather the users’.
Product liability is a field of law that was developed from common-law to give remedy to the consumer of products manufactured and packed against the manufacturer. Previously, before the popular Donoghue v Stevenson case, the privity of contract rule restricted the consumers from suing manufacturers of defective products. Jarvis v. Ford is a good case that highlights strict liability and negligence in product liability. As seen from the paper, the decision by the majority did not entirely dismiss the Defendant’s claim on the inconsistency of the verdict because the court saw these two liabilities as completely distinct. The court also objected to the defendant’s failure to indicate the specific error in the verdict. The dissenting opinion in a detailed manner showed the similarity between the two liability theories and that one could not take a position in favor of one theory and against the other. Considering the results of the analysis of this case, one cannot help making a recommendation that the reviewing court ought to have set aside the judgment of the lower court and the jury’s verdict by terming it as a miss-trial, hence ordering a re-trial.