General Motors Corp. v. Rita L. Iracheta, Administrator of the Estates of David Iracheta, Deceased, and Edgar Iracheta, Deceased

Summary

The Supreme Court of Texas reversed the court of appeals and rendered judgment for General Motors in a products-liability wrongful-death action arising from a vehicle fire. The Court held that the plaintiffs failed to present competent, reliable evidence that a defect in the vehicle's fuel system caused the second fire that killed Edgar Iracheta. The Court also held that an objection to the plaintiff's improper personal expression of gratitude to the jury was timely under the unusual circumstances.

Holdings

1. There was no evidence that the Toronado's alleged siphoning defect caused the second fire in which Edgar Iracheta died; therefore, the plaintiff was not entitled to recover against General Motors.
2. Expert testimony that is conclusory, speculative, unsupported by an adequate basis, or internally irreconcilable is not competent evidence and cannot support a judgment, even if the witness is credentialed or the testimony was admitted without objection.
3. An objection to the reliability of expert testimony is timely when made after cross-examination reveals the deficiency; counsel need not anticipate a defect before it becomes apparent.
4. In the unusual circumstances presented, a party's personal expression of gratitude to the jury at the close of the case was incurable error and did not require an immediate objection to preserve the complaint.

Questions Presented

1. Whether legally sufficient evidence supported the jury's finding that a design defect in the Toronado's fuel system caused the second fire and Edgar Iracheta's death.
2. Whether the expert testimony offered to establish the location and cause of the fuel leak was qualified, reliable, and competent evidence under Texas Rule of Evidence 702 and Texas law governing conclusory expert opinions.
3. Whether General Motors timely preserved its objections to the reliability of the expert testimony.
4. Whether General Motors timely preserved its complaint about the grandmother's personal expression of gratitude to the jury and whether that conduct constituted incurable jury argument or trial error.

Disposition

reversed