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Adams v. Toyota Motor Corp. - 867 F.3d 903 (8th Cir. 2017)


Other similar instances (OSI) evidence may be relevant to prove the defendant's notice of defects, the defendant's ability to correct known defects, the magnitude of the danger, the product's lack of safety for intended uses, or causation. Fed. R. Evid. 401. Evidence of prior accidents is admissible only if the proponent of the evidence shows that the accidents occurred under circumstances substantially similar to those at issue in the case at bar. An OSI need not occur in precisely the same manner in order to qualify as being substantially similar.


On June 10, 2006, Koua Fong Lee was driving his 1996 Toyota Camry on the interstate. When Lee exited the interstate, the Camry failed to come to a stop and rear-ended another car waiting at a stoplight, killing three of the other car's five passengers and injuring others, including those in Lee's vehicle. Lee was convicted of vehicular homicide, but his conviction was vacated after Toyota recalled several models of their Camry for issues related to unintended acceleration, ultimately leading to new evidence in Lee's case. In the meantime, plaintiffs Jassmine D. Adams and other family members of the deceased accident victims filed a lawsuit against defendants Toyota Motor Corporation and others in state court in 2010, alleging, among other things, personal injury and wrongful death based on strict product liability, and Lee eventually joined as a plaintiff. Toyota removed the action to federal district court. Following a four-week trial, a jury found Lee 40 percent and Toyota 60 percent at fault for the collision. The district court entered judgment on the verdict. Toyota appealed.


Were Other Similar Instances (OSI) admissible in a products liability action?




The appellate court affirmed in part and reversed and remanded in part the district court's judgment. The court observed that admitting similar-incident evidence carried the risk of raising extraneous controversial points, leading to a confusion of the issues, and presenting undue prejudice disproportionate to its usefulness. The court ruled that the district court took those concerns into consideration before admitting evidence of a limited number of substantially similar incidents, and in so doing, the district court did not abuse its discretion. Among its other rulings, the court vacated that part of the judgment that awarded one plaintiff prejudgment interests and reversed that part of the judgment that reduced that same plaintiff's damage award to account for a prior settlement she entered into with Lee and Lee's insurance provider.

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