Adams v. Toyota Motor Corp., No. 15-2507 (8th Cir. 2017)Annotate this Case
This case arose out of an accident that killed three people and injured others. Family members of the deceased and the driver filed suit against Toyota alleging various claims. The jury found that the driver was 40 percent at fault and Toyota was 60 percent at fault for the collision. The Eighth Circuit held that the district court did not abuse its discretion by admitting evidence of a limited number of substantially similar incidents; the district court did not abuse its broad discretion by allowing plaintiff's expert's opinion under FRE 702; the district court did not err by denying Toyota's motion for judgment as a matter of law where plaintiffs presented sufficient evidence from which a jury could find that the 1996 Camry contained a design defect; the district court erred in awarding prejudgment interest and vacated the award of prejudgment interest to Plaintiff Trice; and Trice's award should not be reduced by the amount that Plaintiff Devyn previously recovered from the driver and the driver's insurers. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings.
Court Description: Kelly, Author, with Loken and Murphy, Circuit Judges] Civil case - Products Liability. In action involving unintended acceleration in Toyota Camrys, the district court carefully weighed the admission of other similar incident evidence and did not abuse its discretion in admitting a limited number of substantially similar incidents; argument that the district court erred in allowing plaintiffs' expert to give his opinion regarding the cause of the unintended acceleration rejected as this testing supported his theory of the defect and the evidence he relied on was sufficient to support the theory; plaintiffs presented sufficient evidence from which a jury could find that the 1996 Camry contained a design defect which was the proximate cause of the accidents at issue; taking into account the plain language of Minn. Stat. Ann. Section 549.09 regarding prejudgment interest, lower state court decisions and the purpose of the statute, the court predicts that the Minnesota Supreme Court would conclude that prejudgment interest is not available for judgments that encompass multiple types of interest - some of which are subject to interest under the statute and some of which are not - when it is impossible to differentiate between the types of damages included in the judgment, and the district court erred in awarding prejudgment interest; with respect to plaintiff Trice's cross-appeal, the district court erred in reducing her wrongful death damages award by the amount her decedent recovered from the driver of the other vehicle and his insurers.
The court issued a subsequent related opinion or order on August 11, 2017.