Reliance Steel & Aluminum Co. v. Sevcik

Summary

The Supreme Court of Texas held that evidence of a defendant corporation's gross annual sales was inadmissible in a negligence action because it had no logical relevance and posed a substantial risk of prejudicing the jury. The court further held that admission of the evidence was harmful in the context of the damages verdict, reversed the court of appeals' judgment, and remanded for a new trial.

Holdings

1. Evidence of Reliance's gross annual sales was inadmissible because it had no logical tendency to make any material issue more or less probable and carried a substantial risk of prejudicing the jury by suggesting that Reliance could afford a large judgment.
2. The erroneous admission of Reliance's gross-sales evidence was harmful because it probably caused rendition of an improper judgment.

Questions Presented

1. Whether evidence of Reliance's gross annual revenues was relevant and admissible in a negligence action when punitive damages were not at issue and the plaintiffs pleaded only vicarious liability.
2. Whether the trial court abused its discretion by admitting evidence of Reliance's $1.9 billion in gross annual sales.
3. Whether the erroneous admission of the wealth evidence was harmless under Texas Rule of Appellate Procedure 44.1.

Disposition

reversed_and_remanded