Stephen Brent Wheeler v. John Deere Company

Summary

The Tenth Circuit reviewed a Kansas strict-products-liability judgment arising from the plaintiff’s loss of an arm in a John Deere combine’s vertical unloading auger. The court held that the trial court improperly admitted certain evidence of other accidents and subsequent design changes, while concluding that the challenged jury instructions adequately reflected Kansas law. It reversed the judgment and remanded for a new trial.

Holdings

1. The district court did not abuse its discretion by admitting live testimony from five witnesses who suffered substantially similar injuries while clearing Titan-series combine augers.
2. The district court erred by allowing Wheeler to impeach Deere's expert with accidents for which the court had not first found substantial similarity.
3. The district court erred by admitting evidence of subsequent design changes after Deere stipulated that the alternative design was technologically and economically feasible.
4. The district court properly admitted portions of safety-committee exhibits concerning Deere's awareness of a possible warning problem and the need for a warning decal near the cleanout door.
5. The jury instructions, considered as a whole, adequately stated Kansas strict-products-liability and comparative-fault law, including the parties' respective duties.
6. The district court properly denied Deere's motion for a directed verdict because Wheeler presented sufficient evidence for a rational jury to find that the combine was unreasonably dangerous and inadequately warned.

Questions Presented

1. Whether evidence of other accidents involving Titan series combines was properly admitted to show a dangerous condition and to impeach Deere's expert.
2. Whether evidence of subsequent design changes was admissible after Deere stipulated that the alternative design was technologically and economically feasible.
3. Whether the jury instructions correctly stated Kansas strict-products-liability and comparative-fault law.
4. Whether the district court properly denied Deere's motion for a directed verdict on the adequacy of the warning and consumer-expectations issues.

Disposition

reversed_and_remanded