James Coterel v. Dorel Juvenile Group, Inc.
2016 U.S. App. LEXIS 12363
8th Cir.2016Background
- Plaintiffs James Coterel and Crystal Naylor sued Dorel Juvenile Group after their 23‑month‑old son, Jacob, drowned after leaving the house; plaintiffs alleged the Dorel doorknob cover was defective and that Dorel was negligent.
- The doorknob cover was a two‑piece plastic device that spins unless two pads are pressed; packaging warned it required adult supervision and to discontinue use when a child can defeat it.
- Parents had installed a chain lock after believing Jacob had learned to defeat the cover; appellees say the chain lock was sometimes relied on and that the cover was not a substitute for a lock.
- At trial Dorel asserted defenses including sole cause and comparative fault; the district court denied Dorel’s late motion to convert comparative‑fault into a contribution counterclaim and excluded comparative‑fault arguments under Missouri wrongful‑death precedent.
- The district court admitted evidence that on the night of the death Naylor failed to latch the chain lock and that Coterel had told an investigator Jacob could defeat the cover; plaintiffs objected to relevance and hearsay but were overruled.
- After a six‑day trial a jury returned a general verdict for Dorel; plaintiffs moved for a new trial alleging the admitted evidence tainted the verdict, but the district court denied the motion and the court of appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of evidence that Naylor did not latch the chain lock the night of the death | Evidence was irrelevant or, at most, contributory fault which Dorel could not assert to reduce liability under Missouri wrongful‑death law | Evidence was relevant to Dorel’s sole‑cause defense and to challenge causation; not barred as comparative fault | District court did not abuse discretion admitting the evidence; any error did not prejudice plaintiffs |
| Admissibility of Coterel’s prior statement that Jacob could defeat the cover (hearsay) | Statement was hearsay and should be excluded | Statement bore on causation and Dorel’s theory that parents relied on a lock rather than the cover | District court did not clearly err in admitting the testimony; admission not shown to be prejudicial |
| Whether the exclusion of comparative‑fault argument required a different verdict form or new trial | Plaintiffs argued exclusion left jury without lawful mechanism to apportion fault and made admission of fault‑related evidence unduly prejudicial | Dorel argued it could present sole‑cause theory and contest causation; jury could find no defect or lack of causation | Court held the general verdict prevents knowing the jury’s reason; plaintiffs failed to show prejudice or miscarriage of justice |
| Whether a new trial was required given evidentiary rulings | Plaintiffs: evidentiary errors tainted jury’s verdict and warrant new trial under Rule 59 | Dorel: any errors were harmless; jury could have found no defect or lack of causation independent of challenged evidence | No reversible abuse of discretion; plaintiffs did not prove the errors affected substantial rights — affirmance |
Key Cases Cited
- Burris v. Gulf Underwriters Ins. Co., 787 F.3d 875 (8th Cir. 2015) (standard of review for evidentiary rulings and new‑trial denials)
- Qualley v. Clo‑Tex Int’l, Inc., 212 F.3d 1123 (8th Cir. 2000) (assessing whether evidentiary error prejudicially influenced outcome by reference to jury verdict)
- Regions Bank v. BMW N. Am., Inc., 406 F.3d 978 (8th Cir. 2005) (requiring showing that evidentiary admission prejudicially influenced jury)
- Lovett ex rel. Lovett v. Union Pac. R.R., 201 F.3d 1074 (8th Cir. 2000) (general verdicts prevent knowing jury’s basis and preclude speculation of prejudice)
- Teeter v. Mo. Highway & Transp. Comm’n, 891 S.W.2d 817 (Mo. 1995) (Missouri rule limiting defendant’s ability to reduce liability in wrongful‑death action by comparing beneficiaries’ fault)