Rozier v. Ford Motor Co.

Brief Fact Summary.

Rozier appealed the trial court’s decision not to grant her a new trial after Ford Moto Co. failed to produce a document requested during discovery.

Synopsis of Rule of Law.

A party is entitled to a new trial if the opposing party fails to disclose a document requested during discovery.

Facts.

Rozier was killed when his Ford’s fuel tank exploded after being struck from behind. His wife filed suit against Ford Motor Co. (Ford) claiming that Ford was negligent in designing Rozier’s fuel tank. When the trial court found in favor of Ford, Rozier filed a 60(b)(3) motion for a new trial. Because Ford failed to produce the “Confidential Cost Engineering Report” (Report), that compared the cost of labor and parts for two different Ford fuel tanks. Ford found the document but did not make it available to Rozier. Rozier appealed when the trial court denied her request for a new trial.

Issue.

Whether a party is entitled to a new trial if the opposing party fails to disclose a document requested during discovery?

Held.

Yes. The holding is reversed and Rozier is entitled to a new trial. Despite Ford’s counsel knowing of the Report a week prior to the trial, Ford failed to produce the document, affecting the outcome of the case.

Discussion.

Federal Rule of Civil Procedure (FRCP) 60(b)(3) relieves a party from final judgment due to fraud, misrepresentation, or misconduct by an opposing party.