Trial court rulings on the admissibility of evidence, whether in limine or during trial, are generally reviewed for abuse of discretion. On appeal, a trial court's decision to admit or not admit evidence, whether made in limine or following a hearing pursuant to Evid. Code, § 402, is reviewed for abuse of discretion. The trial court's error in excluding evidence is grounds for reversing a judgment only if the party appealing demonstrates a miscarriage of justice - that is, that a different result would have been probable if the error had not occurred.
Plaintiff motorist suffered a severe spinal injury, resulting in quadriplegia, when his sport utility vehicle rolled over following a chain of collisions. Plaintiff sued defendant manufacturer alleging claims, among others, for strict liability based on defective design. Following a bench trial, the Los Angeles County Superior Court, California entered a judgment in the amount of $21,654,000 in favor of plaintiff. The manufacturer appealed and the judgment was affirmed.
Was the trial court's finding of strict liability under the risk-benefit test amply supported by the record and fully justified the judgment in favor of plaintiff?
The court concluded the trial court's finding of strict liability under the risk-benefit test was amply supported by the record and fully justified the judgment in favor of plaintiff. With respect to stability design, plaintiff established that a comparable production vehicle would tip under evasive steering maneuvers and that slight modifications to the track width and center of gravity of the vehicle dramatically improved its rollover resistance. Plaintiff proved these improvements could be achieved at a modest cost. The manufacturer did not rebut any of these showings. Moreover, the manufacturer's senior engineer acknowledged these modifications were available and could have been made at the time plaintiff's vehicle was manufactured. Substantial evidence supported the trial court's failure to warn finding. Rather than warn of the dangers of rollover or roof crush, the vehicle's window sticker informed plaintiff the vehicle had a steel inner body cage and a steel roof panel, among other things, leading him to believe the vehicle was not defectively designed. Substantial evidence also supported the award of economic damages.