Robert Chism v. CNH America LLC, No. 10-1701 (8th Cir. 2011)
Annotate this CaseAppellant brought a products liability lawsuit against appellee after appellant's left arm was amputated below his elbow as the result of a farming accident on a 1998 New Holland Model 648 hay baler. A jury found in favor of appellee and appellant appealed challenging six of the district court's evidentiary rulings. The court affirmed the judgment and held that the district court did not abuse it's discretion by admitting two jury verdicts favorable to appellee in other cases involving accidents substantially similar to appellant's where appellant's opening statements and theme increased the probative value of the verdicts; by excluding other accidents involving appellee's hay balers where admitting similar-incident evidence threatened to raise extraneous controversial issues, confuse the issues, be more prejudicial than probative, and create a trial within a trial for each previous incident; by excluding expert testimony of the pinch point and the baler tire where the evidence was minimally probative, cumulative, and would have unnecessarily confused the issue; and by admitting the total number of Series 6 balers manufactured where admitting the total number provided context for the jury to consider the substantially similar incidents. The court also held that the district court did not abuse its discretion by excluding photographs and exhibits that had limited probative value and would unduly confuse the jury. The court further held that the district court did not err in excluding expert witness testimony regarding the Engineering Code of Ethics where such testimony was irrelevant because there was no legal force or effect to those rules and no foundation.
Court Description: Civil case - products liability. District court did not abuse its discretion by admitting evidence of two jury verdicts favorable to defendant in cases involving substantially similar accidents; exclusion of other incidents involving defendant's balers was proper as the other incidents were not substantially similar to plaintiff's accident, and their slight probative value was outweighed by the danger of confusing the jury; evidence concerning proximity of pinch point where plaintiff's arm was caught to the baler's tire was properly excluded as the accident did not involve plaintiff standing on the tire; admission of evidence concerning the number of balers manufactured was not plain error; exclusion of pictures and video of newer model balers was not error; testimony about the Engineering Code of Ethics was properly excluded as irrelevant since the code has no legal force or effect.
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