Jarvis v. Ford Motor Co.

Brief Fact Summary.

Jarvis (Plaintiff) sued Ford Motor (Defendant) for negligence and strict liability on the basis that a design defect in their minivan caused sudden acceleration.

Synopsis of Rule of Law.

Under Rule 51, a party waives the right to object to a jury instruction if the party fails to “state distinctly the matter objected to and the grounds of the objection.”

Facts.

Jarvis (Plaintiff) sued Ford Motor (Defendant) for negligence and strict liability on the basis that a design defect in their minivan caused sudden acceleration.

Issue.

Did the Defendant waive its right to object to the juror instruction under Rule 51?

Held.

Yes, under Rule 51 the Defendant waived its right to object to the jury instruction. The jury verdict is reinstated.

Discussion.

The Court determined that the district court should have applied Rule 51 before granting Defendant’s motion for judgment as a matter of law. Under Rule 51, the Defendant failed to state distinctly the matter objected to and the grounds of the objection. The Defendant did not object to the court sending both issues of negligence and strict liability to the jury, and did not present legal arguments in favor of charging only one. Thus, the Defendant waived the right to object to the jury instruction.