Bierria v. Dickinson Manufacturing Co., Ltd.

Summary

The Supreme Court of Alaska affirmed a judgment for Dickinson Manufacturing in a products-liability action arising from a fishing boat fire allegedly caused by a defective stove. The court held that the jury had an evidentiary basis to find that the defect arose after the stove left the manufacturer’s possession and upheld evidentiary rulings excluding evidence of certain other boat fires and admitting testing conducted in an on-shore warehouse.

Holdings

1. The superior court did not abuse its discretion in denying a new trial because evidence supported the jury's finding that the stove's defect arose after it left Dickinson's possession.
2. The superior court did not abuse its discretion by excluding evidence of the HIGH ROLLER, C MARIE, SHEARWATER, and NATALIA fires, while evidence concerning the MAD GAFFER fire was relevant but could not support error because Bierria chose not to present it.
3. The superior court did not abuse its discretion by admitting Dr. Paul Blotter's tests of the Dickinson stove despite the tests' not having been conducted aboard a seagoing vessel.

Questions Presented

1. Whether the evidence supporting the jury's finding that the stove was not defective when it left Dickinson's possession was so lacking or unconvincing that denial of a new trial constituted an abuse of discretion.
2. Whether the superior court abused its discretion by excluding evidence of certain other boat fires involving Dickinson stoves.
3. Whether the superior court abused its discretion by admitting expert tests conducted on a Dickinson stove in an on-shore warehouse rather than under seagoing conditions.

Disposition

affirmed