Joyce Stockton v. Ford Motor Company-Partial Dissent
W2016-01175-COA-R3-CV
| Tenn. Ct. App. | May 12, 2017Background
- Mrs. Stockton sued Ford alleging negligence based on exposure risk to a household member from a Ford product; the trial court found a duty and the case proceeded to jury trial.
- Ford moved pretrial and for directed verdict arguing it owed no duty to Stockton; those motions were denied and the case reached this Court on appeal.
- The central legal question is whether Ford owed a duty of care to a non-user household member under Tennessee precedent.
- The Tennessee Supreme Court’s decision in Satterfield v. Breeding Insulation created a framework for courts to determine duty: foreseeability plus an eight-factor balancing test.
- The majority below applied a broad Restatement (Third) approach treating duty as the default unless exceptional public-policy reasons to deny it; Judge Stafford (concurring/dissenting in part) argued the court should instead apply the Satterfield factors de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ford owed a legal duty to Stockton (threshold negligence element) | Stockton: risk to household member was foreseeable and evidence supports existence of duty | Ford: no Tennessee precedent extends manufacturer’s duty to users’ household members; no duty exists | Majority: affirmed trial court’s denial of Ford’s motion on duty (treated duty as default); Stafford J.: would apply Satterfield balancing and decide duty de novo |
| Appropriate legal standard to determine duty | Use Satterfield foreseeability + eight-factor balancing to decide duty | Adopt Restatement (Third) default rule that duty exists unless public policy limits it | Majority relied on Restatement approach; Stafford disagreed and urged Satterfield framework |
| Effect of procedural posture (trial on the merits vs. pretrial dismissal) on who decides duty | Stockton: once case tried, evidence supports duty and court may defer to trial outcome | Ford: duty is a legal question for the court regardless of trial posture and should be reviewed de novo | Stafford: duty remains a question of law to be analyzed by the court de novo even after trial; majority treated duty as resolved below |
| Whether appellate court should analyze duty before addressing jury-instruction errors | Stockton: proceed to address instructional errors after affirming duty | Ford: duty is threshold and must be resolved before jury instruction issues | Stafford: duty must be addressed first using Satterfield factors; he dissented in part because the majority did not perform that analysis |
Key Cases Cited
- Satterfield v. Breeding Insulation Co., 266 S.W.3d 347 (Tenn. 2008) (adopts foreseeability requirement plus eight-factor balancing test to decide existence of duty)
- Giggers v. Memphis Hous. Auth., 277 S.W.3d 359 (Tenn. 2009) (duty is essential element of negligence claim)
- McCall v. Wilder, 913 S.W.2d 150 (Tenn. 1995) (duty as required element of negligence)
- Burroughs v. Magee, 118 S.W.3d 323 (Tenn. 2003) (factors relevant to duty analysis cited by Satterfield)
- Hale v. Ostrow, 166 S.W.3d 713 (Tenn. 2005) (discusses duty as threshold legal question)
- Marla H. v. Knox Cty., 361 S.W.3d 518 (Tenn. Ct. App. 2011) (court applied Satterfield factors post-trial to analyze duty)
- Bloodworth v. Stuart, 428 S.W.2d 786 (Tenn. 1968) (Court of Appeals bound by Tennessee Supreme Court precedent)