Smith v. Volkswagen Southtowne, Inc.
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The Supreme Court reversed in part and affirmed in part the judgment of the district court granting Volkswagen SouthTowne's motion for judgment as a matter of law and a new trial after Plaintiff was awarded $2,700,000 on her negligence and strict liability claims, holding that SouthTowne was not entitled to judgment as a matter of law or a new trial.
SouthTowne sold Plaintiff a vehicle that was subject to a safety recall because of defective fuel injection lines. After buying the car, Plaintiff was diagnosed with carbon monoxide poisoning. A mechanic discovered that the safety recall had not been performed on Plaintiff's vehicle. A jury returned a verdict in favor of Plaintiff, but the district court entered post-trial orders concluding that Plaintiff had failed sufficiently to establish the applicable standard of care. The Supreme Court reversed in part, holding (1) the cumulative evidence adduced at trial was legally sufficient to satisfy the element of causation; and (2) the trial court erred in basing its ruling conditionally granting a new trial to SouthTowne because the ruling was based on issues that Plaintiff was not given notice and an opportunity to be heard on.
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