CHRYSLER GROUP, LLC v. WALDEN Et Al.
339 Ga. App. 733
| Ga. Ct. App. | 2016Background
- Four-year-old Remington Walden died when a 1999 Jeep Grand Cherokee’s rear-mounted fuel tank ruptured after a rear-end collision and the vehicle ignited.
- Plaintiffs sued Chrysler (now FCA US) alleging reckless/wanton design/sale and failure to warn; co-defendant driver Harrell was 1% at fault and not appealing.
- Jury awarded $120M (wrongful death) and $30M (pain & suffering); trial court conditionally denied new trial but remitted to $30M and $10M respectively, judgment entered on remitted amounts.
- Plaintiffs introduced evidence Chrysler knew rear-mounted tanks were vulnerable, could have placed tanks midship, and that fuel leakage caused the fire.
- Plaintiffs offered 17 prior rear-impact incidents with similar Jeep tank placement and an NHTSA ODI recall-request letter reflecting a tentative defect finding; Chrysler objected to several evidentiary rulings and to verdict size.
- Court of Appeals affirmed denial of directed verdicts, admissibility rulings (other-incident evidence, ODI letter, CEO compensation for bias), exclusion of some Chrysler experts, and remittitur amount.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether directed verdict was proper on wanton/reckless-design claim | Chrysler knew tank location was dangerous and consciously continued sale; evidence supports wanton/reckless conduct | Compliance with FMVSS, industry practice, and limited pre-sale incidents preclude wanton/reckless finding | Denial affirmed — any-evidence standard satisfied; compliance and prevalence are jury considerations, not conclusive defenses |
| Whether directed verdict was proper on failure-to-warn (no-warning) claim | Complete absence of warning allows jury to find proximate causation without proof plaintiffs would have read a warning | Plaintiffs failed to prove they would have seen/read any warning, so causation lacking | Denial affirmed — no precedent requires proof a warning would have been read when none was provided; proximate cause is for the jury |
| Admissibility of other-incident evidence (17 incidents) | Incidents show Chrysler had notice of danger from rear-mounted tanks; common design/causation present | Incidents involved different models and lacked substantial similarity | Admission affirmed — trial court did not abuse discretion; plaintiffs showed common design and common causation |
| Admissibility of NHTSA/ODI recall-request letter | Letter and investigative timeline are admissible (public record, context) to show ODI’s initial findings and explain later closure | Letter is hearsay/tentative and untrustworthy (Toole) and thus inadmissible | Admission affirmed — offered for non-hearsay purposes (credibility/timeline) and as public record; not an abuse of discretion |
Key Cases Cited
- Teklewold v. Taylor, 271 Ga. App. 664 (court reviews directed verdict under any-evidence standard)
- Key Safety Sys. v. Bruner, 334 Ga. App. 717 (any-evidence/denial-of-directed-verdict standard and proximate-cause discussion)
- Doyle v. Volkswagenwerk Aktiengesellschaft, 267 Ga. 574 (compliance with federal standards is relevant but not conclusive)
- Banks v. ICI Americas, 264 Ga. 732 (state-of-the-art/federal compliance not dispositive on design defect)
- Colp v. Ford Motor Co., 279 Ga. App. 280 (substantial-similarity requires common design, defect, and causation)
- Cooper Tire & Rubber Co. v. Crosby, 273 Ga. 454 (trial court’s admission of other-incident evidence reviewed for abuse of discretion)
- Toole v. McClintock, 999 F.2d 1430 (11th Cir.) (agency reports with tentative findings may be inadmissible where untrustworthy; discussed and distinguished)