Scott v. Ford Motor Co.
169 Cal. Rptr. 3d 823
Cal. Ct. App.2014Background
- Scott, a long-time auto mechanic and service-station owner, was exposed to asbestos from brakes and clutches and developed mesothelioma; he and wife sued Ford among many defendants.
- The case proceeded to trial against Ford; jury found Ford liable on failure-to-warn and design-related theories; punitive damages were barred under Michigan law as applied.
- The trial court denied Ford’s JNOV motion and the court applied Michigan law to preclude punitive damages at trial.
- Ford argued the sophisticated user doctrine provided a complete defense to failure-to-warn and design defects; the court found the doctrine did not supply a complete defense given the lack of knowledge in the 1960s-1970s.
- The appellate court held Michigan law should not govern punitive damages in California; the case was remanded for a new punitive-damages trial under California law.
- Evidence of Ford’s internal mesothelioma investigation was admitted and reviewed for relevance and potential prejudice; the court found it admissible and not reversible error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sophisticated user doctrine as complete defense | Scott’s exposure began before knowledge matured; no evidence the class knew of risks by mid-1960s | Advanced knowledge by the industry should have barred warnings | Not a complete defense; warning claims remain valid |
| Efficacy of warning | Timely warnings could have prevented exposure | Warnings would not have changed Scott’s behavior | Sufficient evidence supports warning could have prevented exposure |
| Admission of internal investigation evidence | Evidence shows Ford's awareness of risks | Prejudicial; should be excluded under 352 | Evidence was relevant and not prejudicial under Watson standard |
| Punitive damages under Michigan law | Michigan law should bar punitive damages; California law applies | Michigan policy should shield Michigan-domiciled defendants | Remand for trial on punitive damages under California law |
Key Cases Cited
- Johnson v. American Standard, Inc., 43 Cal.4th 56 (Cal. 2008) (sophisticated user doctrine applied to warning duty)
- Sullivan v. Oracle Corp., 51 Cal.4th 1191 (Cal. 2011) (governmental interests/conflicts of law analysis)
- Hasson v. Ford Motor Co., 32 Cal.3d 388 (Cal. 1982) (substantial similarity rationale for evidence of defect or knowledge)
- McCann v. Foster Wheeler LLC, 48 Cal.4th 68 (Cal. 2010) (caution against domicile-based importation of laws)
- Burns v. Van Laan, 367 Mich. 485 (Mich. 1962) (Mich. punitive damages ban; compensation, not punishment)