Bouret-Echevarria v. Caribbean Aviation Maint. Corp., No. 13-2549 (1st Cir. 2015)Annotate this Case
In 2008, the decedent was killed in a helicopter crash. The decedent’s widow and children (collectively, Appellants) filed a products liability action against the helicopter’s manufacturer and repair company. The jury returned a unanimous verdict finding that the defendants were not negligent. Approximately eighteen months after the jury returned its verdict, Appellants were allegedly told that the verdict was influenced by the jurors’ improper knowledge of a confidential settlement offer. Appellants filed a motion pursuant to Fed. R. Civ. P. 60(b)(6) seeking an evidentiary hearing to explore the jury taint. The district court denied the motion on the grounds that the filing of the motion was untimely and that the materials filed in support of the motion were insufficient. The First Circuit vacated the district court’s order and remanded for an evidentiary hearing, holding that the court abused its discretion in denying the motion for 60(b) relief without holding such a hearing.