CHRYSLER GROUP LLC v. WALDEN
303 Ga. 358
Ga.2018Background
- In 2012 a rear-end collision caused a 1999 Jeep’s rear-mounted gas tank to rupture and burn four-year-old Remington Walden to death; plaintiffs sued Chrysler and the driver for wrongful death claiming design defect and willful/reckless conduct to avoid Georgia’s ten-year repose statute.
- Plaintiffs emphasized that NHTSA’s ODI recommended recalling certain Jeep models with rear fuel tanks but Chrysler’s CEO Sergio Marchionne met with federal officials and the Jeep model at issue was excluded from the recall; Marchionne testified and denied improper influence.
- At trial plaintiffs elicited testimony from Chrysler’s COO about Marchionne’s compensation (totaling over $68 million); the trial court overruled Chrysler’s relevance and wealth objections and admitted the evidence; plaintiffs referenced the compensation in closing to argue damages.
- The jury returned a large verdict finding Chrysler 99% at fault and awarding $150 million; the trial court reduced (remitted) the award; the Court of Appeals affirmed admission of compensation evidence holding bias evidence is always admissible under OCGA § 24-6-622.
- The Georgia Supreme Court granted certiorari to decide whether evidence of a non-party CEO’s compensation is categorically admissible to show bias (and whether remittitur review erred); it analyzed the new Georgia Evidence Code (Rules 401–403 and 622) and federal precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of CEO compensation to show witness bias | Compensation shows Marchionne’s stake and potential bias favoring Chrysler; relevant under OCGA § 24-6-622 | Evidence was irrelevant or unduly prejudicial; should be excluded (invoking party-wealth principles) | Evidence of a non-party witness’s compensation may be admissible to show bias but is subject to Rule 403 balancing; not automatically admissible in all cases |
| Applicability of the old party-wealth common-law rule | N/A (plaintiffs relied on bias rule) | The common-law rule barring party-wealth evidence should bar compensation evidence | The common-law party-wealth rule was displaced or modified by the new Evidence Code; it does not categorically bar non-party compensation evidence |
| Proper limiting principle between OCGA § 24-6-622 and Rule 403 | OCGA § 24-6-622 permits proof of witness feelings/relationship | § 24-6-622 should not be read to override Rule 403’s unfair-prejudice constraint | Rule 622 does not override Rule 403; bias evidence remains subject to a probative-vs-prejudicial Rule 403 analysis |
| Standard of review and remedy for failure to make a Rule 403 objection at trial | N/A | Chrysler failed to invoke Rule 403 specifically; appellate review should be for plain error only | Because Chrysler did not raise a Rule 403 objection below, appellate review is for plain error; under those facts admission was not plainly erroneous and judgment affirmed |
Key Cases Cited
- Citizens & Southern Nat. Bank v. Haskins, 254 Ga. 131 (discussing construing evidence to support jury verdict)
- Blige v. State, 264 Ga. 166 (stating witness-bias evidence must be read in context of other evidentiary rules)
- Daubert v. Merrell Dow Pharms., 509 U.S. 579 (discussing Rule 402 as baseline for admissibility under the Federal Rules)
- BankAtlantic v. Blythe Eastman Paine Webber, Inc., 955 F.2d 1467 (11th Cir.) (holding chairman’s income was relevant to show bias)
- Olds v. State, 299 Ga. 65 (noting Rule 403 exclusion is extraordinary and used sparingly)
- Honda Motor Co. v. Oberg, 512 U.S. 415 (warning that net-worth evidence risks juror bias against large corporations)