Aldridge v. Forest River, Inc., 2011 U.S. App. LEXIS 4489

Background

Aldridge fell while descending the steps of a 2004 Forest River Georgetown RV when the step controller unexpectedly retracted, causing injuries.
SCS designed and supplied the step controller installed in the Forest River RV; Forest River manufactured and sold the RV.
Plaintiff sued Forest River and SCS in federal court under diversity jurisdiction, alleging strict liability and negligence under Florida law.
Prior to trial, the district court granted Forest River's motion in limine barring arguments that the entire RV was defective and limited the theory to the step controller.
Aldridge sought to amend to assert the RV as a whole was defective; the district court denied the motion to amend.
During trial, the court amended Aldridge’s proposed jury instruction to focus on whether the RV sold with the step controller was defective, rather than solely the controller.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the in limine ruling restricting the defect theory was an abuse of discretion	Aldridge contends the RV defect theory should have been considered.	Forest River argues the case was litigated as a step-controller defect and no surprise occurred.	No abuse; ruling was within discretion and consistent with the record.
Whether the district court abused its discretion in denying leave to amend	Aldridge argued for adding a theory that the entire RV was defective.	Defendants did not consent to the new theory and late amendment would prejudice defense and require reopening discovery.	No abuse; amendment denied due to lack of consent and late stage, with justification in scope and timing.
Whether the jury instruction amendment was improper	Aldridge challenged the modification of the instruction to focus on the RV with the step controller.	The instruction, though amended, tracked the complaint/final pretrial order and the district court acted within discretion.	No abuse; the instruction appropriately framed the issue and was not misleading.
Whether the denial of a new-trial motion was erroneous	New trial should have been granted due to errors in limine and amendment decisions.	The verdict was not against the manifest weight of the evidence and the court acted within its discretion.	No abuse; district court properly denied the motion for new trial.
Whether the claims against SCS were properly resolved	Aldridge challenged the handling of SCS claims beyond the step controller.	Evidence pertained exclusively to the step controller; no error in the SCS outcome.	Affirmed; no error in the SCS portion; evidence concentrated on the step controller.

Key Cases Cited

Von der Ruhr v. Immtech International, Inc., 570 F.3d 858 (7th Cir.2009) (abuse-of-discretion standard for motions in limine)
Gonzalez v. Ingersoll Milling Mach. Co., 133 F.3d 1025 (7th Cir.1998) (district court caseload management and discretion)
United States v. Reed, 2 F.3d 1441 (7th Cir.1993) (principles on discretionary trial management)
Snipes v. Ill. Dep't of Corr., 291 F.3d 460 (7th Cir.2002) (abuse-of-discretion review standard)
In re Rivinius, Inc., 977 F.2d 1171 (7th Cir.1992) (scope of amendments and consent in Rule 15(b)(2))
Matter of Prescott, 805 F.2d 719 (7th Cir.1986) (quotations on amendment timing and impact)
Trustmark Ins. Co. v. Gen. & Cologne Life Re of Am., 424 F.3d 542 (7th Cir.2005) (abuse-of-discretion standard in pleadings and amendments)
Brunt v. Serv. Employees Int'l Union, 284 F.3d 715 (7th Cir.2002) (sound discretion in denial of leave to amend)
J.D. Marshall Int'l Inc. v. Redstart, Inc., 935 F.2d 815 (7th Cir.1991) (discretion in allowing amendments and trial strategy)
Russell v. National R.R. Passenger Corp., 189 F.3d 590 (7th Cir.1999) (analysis of jury instruction clarity and impact)
Spiller v. Brady, 169 F.3d 1064 (7th Cir.1999) (jury instruction review framework)
Heller Int'l Corp. v. Sharp, 974 F.2d 850 (7th Cir.1992) (district court's substantial discretion in wording jury instructions)
Lowe v. Consol. Freightways of Del., Inc., 177 F.3d 640 (7th Cir.1999) (heavy burden to reverse denial of new trial)
Cefalu v. Vill. of Elk Grove, 211 F.3d 416 (7th Cir.2000) (new trial standard and discretion)
Cassisi v. Maytag, 396 So.2d 1140 (Fla. App.1981) (Cassisi inference for product defect in Florida)