Newton v. Ford Motor Co.

Summary

The Supreme Court of Missouri held that the trial court erred by preventing plaintiffs from discussing evidence of post-upgrade fuel-leakage accidents during closing argument after Ford had introduced that evidence at trial. The Court presumed prejudice from the restriction, concluded that Ford had used the ruling to its advantage, reversed the judgment in Ford's favor, and remanded for a new trial. A separate concurring opinion discussed potential issue preclusion concerning damages previously determined in plaintiffs' final judgment against Trade Winds Distributing.

Holdings

1. Once Ford introduced evidence of all 11 post-upgrade accidents into the record, plaintiffs were entitled to discuss that evidence during closing argument, notwithstanding the trial court's earlier ruling limiting admissibility to four pre-Newton accidents.
2. The error was presumed prejudicial, and Ford failed to rebut the presumption because it used the trial court's ruling to argue that the shield upgrade kit had cured the only relevant fuel-system defect while plaintiffs were prevented from presenting contrary inferences from the other accidents.

Questions Presented

1. Whether the trial court erred by barring plaintiffs from discussing during closing argument evidence of 11 post-upgrade rear-impact accidents that had been introduced by Ford's own counsel.
2. Whether the error materially affected the merits of the action and therefore required a new trial.

Disposition

reversed_and_remanded