Joyce Stockton v. Ford Motor Company
W2016-01175-COA-R3-CV
| Tenn. Ct. App. | May 12, 2017Background
- Ronnie Stockton was an automobile mechanic who worked on vehicles (including Fords) and brought asbestos-contaminated brake dust home; his wife Joyce cleaned the shop and laundered his clothes and was later diagnosed with mesothelioma in 2011.
- Plaintiffs sued Ford in Tennessee (after an earlier multi-defendant Illinois action) on products-liability theories (strict liability, negligence, failure to warn), alleging Ford’s asbestos-containing brake products caused Joyce’s illness via take-home exposure.
- At trial plaintiffs argued Ford should have warned Ronnie (who would have protected Joyce); Ford presented evidence Ronnie had prior training and manuals warning about asbestos risks.
- The jury found Ford negligent for failing to warn Joyce (assigning fault among defendants) and awarded compensatory, loss-of-consortium, and punitive damages; the trial court entered judgment and denied post-trial relief.
- On appeal the Court of Appeals vacated and remanded because the jury verdict form and negligence instruction omitted required threshold findings—(1) that the product was defective or unreasonably dangerous and (2) that the plaintiff’s injuries were reasonably foreseeable—creating an inconsistent/unintelligible verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether negligence instruction and verdict form were legally sufficient | Jury could find Ford negligent for failing to warn without separate written findings on defect/unreasonably dangerous or foreseeability | Verdict/instructions were defective because Tennessee law requires a threshold finding that product was defective or unreasonably dangerous and foreseeability must be decided | Reversed and remanded — verdict/instruction defective; verdict inconsistent because jury found negligence without required threshold findings |
| Whether Ford owed a duty to a non‑employee household member (take‑home exposure) | Ford had duty to foreseeable victims of take‑home asbestos exposure; Satterfield supports extending duty beyond employer‑employee | Ford argued no duty to remote/occasional handlers’ family members; duty should be limited | Trial court did not err in allowing duty question to go to jury under Satterfield; duty remains a question of law but here the court declined to dismiss on duty grounds |
| Role of foreseeability in negligence (duty, breach, proximate cause) | Foreseeability supports existence of duty and is for the jury on breach/causation; plaintiff’s injuries were reasonably foreseeable | Foreseeability limits duty and could be decided as a matter of law to bar recovery | Court followed Satterfield: foreseeability is central but trial court properly let the case proceed; on remand jury must be instructed and must make an explicit finding on foreseeability before breach/causation questions |
| Causation/specific evidence of exposure and causal link | Jury may infer causation from evidence of exposure to asbestos from defendants’ products and occupational dust brought home | Ford argued plaintiff failed to prove specific exposure from Ford products or that another warning would have prevented Joyce’s illness | Court did not resolve causation on appeal (pretermitted) — remanded for retrial/clarified verdict form so jury can address causation after affirmative findings on defect and foreseeability |
Key Cases Cited
- Roysdon v. R.J. Reynolds Tobacco Co., 815 F.2d 80 (6th Cir.) (legislature intended Tenn. products-liability statute to permit recovery where product is defective or unreasonably dangerous)
- Browder v. Pettigrew, 541 S.W.2d 402 (Tenn. 1976) (in products-liability negligence claims plaintiff must still establish a defect or that product was unreasonably dangerous)
- Satterfield v. Breeding Insulation Co., 266 S.W.3d 347 (Tenn. 2008) (duty in take‑home asbestos cases; foreseeability and public‑policy balancing guide duty analysis)
- Concrete Spaces, Inc. v. Sender, 2 S.W.3d 901 (Tenn. 1999) (inconsistent or irreconcilable jury verdicts require reversal and remand)
- McInturff v. White, 565 S.W.2d 478 (Tenn.) (an inconsistent verdict is no verdict at all)
- Milliken v. Smith, 405 S.W.2d 475 (Tenn.) (litigants are entitled to a consistent and intelligible verdict)