Summary
The Mississippi Supreme Court affirmed a jury verdict against Cooper Tire in a wrongful-death products-liability action arising from a tire-tread separation and vehicle rollover. The court held that the plaintiffs presented sufficient evidence under the Mississippi Products Liability Act, and it rejected Cooper's challenges to evidentiary rulings, trial arguments, and the compensatory and punitive damages awards.
Holdings
- The Tuckiers presented sufficient evidence to establish a prima facie MPLA claim and to support the jury's finding that the tire was materially defective because bad stock caused a failure of the chemical bond between the rubber and steel belts.
- The trial court did not err in admitting testimony about former Cooper employees' motivations for testifying because the testimony responded to Cooper's attempt to portray the witnesses as biased or motivated by animosity.
- The questioning of the plaintiffs' expert about other Cooper tire cases did not constitute reversible error because Cooper opened the door by attacking the expert's experience and credibility, and the trial court gave a limiting instruction.
- The trial court did not abuse its discretion by allowing the plaintiffs to question witnesses about blank or redacted pages in Cooper's quality-assurance manual after the manual was admitted into evidence without objection.
- The trial court did not abuse its discretion by allowing the plaintiffs' expert to testify about x-rays of the other three tires because Cooper's cross-examination had challenged the expert's inspection of those tires and the x-rays were relevant to rehabilitating his testimony.
- The $485,000 compensatory-damages award, including the $329,000 apportioned to Cooper, was supported by the evidence and was proper.
- The evidence was sufficient to submit punitive damages to the jury, and the $3 million punitive-damages award was not excessive.
Questions Presented
- Whether the Tuckiers presented a prima facie manufacturing-defect claim under the Mississippi Products Liability Act sufficient to withstand Cooper's motion for directed verdict.
- Whether the admission of testimony and references concerning witnesses' motivations, other Cooper tire claims, Cooper's redacted quality-assurance manual, and x-ray evidence constituted reversible error.
- Whether the compensatory-damages award was proper.
- Whether the punitive-damages award was authorized by sufficient evidence and was not excessive.
Disposition
affirmed
Cases Cited (13)
- Sentinel Indus. Contracting Corp. v. Kimmins Indus. Serv. Corp., 743 So. 2d 954, 960 (Miss. 1999)(followed)
- Bass v. State, 597 So. 2d 182, 191 (Miss. 1992)(followed)
- Fleming v. State, 604 So. 2d 280, 291 (Miss. 1992)(followed)
- Eakes v. State, 665 So. 2d 852, 868 (Miss. 1995)(followed)
- Florence v. State, 755 So. 2d 1065, 1070 (Miss. 2000)(followed)
- Fielder v. Magnolia Beverage Co., 757 So. 2d 925, 937 (Miss. 1999)(followed)
- General Motors Corp. v. Jackson, 636 So. 2d 310, 311 (Miss. 1992)(followed)
- Valley Forge Ins. Co./CNA Ins. Co. v. Strickland, 620 So. 2d 535, 541 (Miss. 1993)(followed)
- Andrew Jackson Life Ins. Co. v. Williams, 566 So. 2d 1172, 1190-91 (Miss. 1990)(followed)
- Banker's Life & Cas. Co. v. Crenshaw, 483 So. 2d 254, 278 (Miss. 1985)(followed)
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Court Document
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