Jassmine D. Adams v. Toyota Motor Corporation
867 F.3d 903
| 8th Cir. | 2017Background
- On June 10, 2006, Koua Fong Lee’s 1996 Toyota Camry failed to stop while exiting an interstate ramp, rear-ending an Oldsmobile and killing three passengers and severely injuring others. Lee was initially convicted of vehicular homicide; that conviction was later vacated after new evidence about Toyota Camry unintended-acceleration issues emerged.
- Family members of the deceased sued Toyota in state court (product liability, wrongful death, strict liability); the case was removed to federal court and tried to a jury.
- Plaintiffs presented (a) testimony from three other 1996 Camry drivers describing similar unintended-acceleration incidents (OSI evidence), and (b) expert mechanical testimony (John Stilson) that heat trapped under a plastic dust cover could cause throttle pulleys to bind, producing unintended acceleration.
- Toyota moved to exclude OSI evidence and Stilson’s testimony, and later moved for judgment as a matter of law (JAML) on design-defect and causation grounds; the district court admitted the evidence and denied JAML.
- The jury apportioned fault (Toyota 60%, Lee 40%) and awarded approximately $14 million; the district court reduced one plaintiff’s award for a prior settlement and awarded prejudgment interest.
- On appeal, the Eighth Circuit affirmed the admission of OSI evidence and Stilson’s testimony and the denial of JAML, vacated the prejudgment-interest award, and held the district court erred in offsetting (pro tanto) the wrongful-death award by amounts previously received by the decedent during life.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of OSI evidence (other-similar-incidents) | OSIs are relevant to defect, notice, magnitude of danger, and causation; the three witnesses were substantially similar to Lee’s incident | OSIs were not shown to be caused by the same defect and therefore were inadmissible | Admitted: district court did not abuse discretion; circumstances were substantially similar and limits (three witnesses) minimized prejudice |
| Admissibility of expert (Stilson) under Rule 702/Daubert | Stilson used accepted testing protocols, explained methodology and conclusions linking heat-induced pulley sticking to unintended acceleration | Toyota attacked testing modifications (repositioned cruise-control arm) and causation conclusions as unreliable/speculative | Admitted: court did not abuse its gatekeeping role; methodology and application were sufficiently reliable for jury consideration |
| Sufficiency of evidence / JAML on design defect and causation | Plaintiffs: Stilson’s tests, OSIs, and eyewitness accounts support that design defect caused the crash | Toyota: competing expert testing showed temperatures wouldn’t reach levels causing sticking; alternative causes (dirty throttle, pedal misapplication) | Denied: reasonable jury could credit plaintiffs’ evidence and infer defect was a substantial factor in causing the accident |
| Prejudgment interest under Minn. Stat. § 549.09 | Trice argued prejudgment interest appropriate on awarded damages | Toyota argued future damages are exempt and lump-sum award made apportionment impossible | Reversed on prejudgment interest: where lump sum contains both interestable pecuniary and non-interestable future damages and apportionment is impossible, prejudgment interest is not allowed |
| Offset (pro tanto) for prior release/settlement | Trice: prior release signed as guardian for the living child (Devyn) should not reduce wrongful-death recovery for next of kin | Toyota: release and settlement should offset wrongful-death recovery pro tanto | Reversed: release executed on behalf of the living decedent relates to the decedent’s personal claim; wrongful-death trustee recovers for next of kin and is not offset by amounts the decedent received while alive |
Key Cases Cited
- Daubert v. Merrell Dow Pharm., 509 U.S. 579 (expert-admissibility gatekeeping; focus on principles and methodology)
- Kumho Tire Co. v. Carmichael, 526 U.S. 137 (trial court gatekeeping extends to non-scientific expert methodology)
- Hale v. Firestone Tire & Rubber Co., 756 F.2d 1322 (OSI admissible only if accidents occurred under substantially similar circumstances)
- Lewy v. Remington Arms Co., 836 F.2d 1104 (OSI evidence admissibility guided by model and circumstance similarity)
- Arabian Agri. Servs. Co. v. Chief Indus., 309 F.3d 479 (abuse-of-discretion standard for OSI evidence admission)
- Torbit v. Ryder, 416 F.3d 898 (focus on totality of circumstances in assessing similarity of other-incident evidence)