Jarvis v. Ford Motor Co.

Brief Fact Summary.

Jarvis sued Ford Motor Co. (Ford) under strict liability and negligence claims.

Synopsis of Rule of Law.

Under Federal Rule of Civil Procedure 51, a party waives the right to objection if the party fails to object, state the matter they are objecting to, and the grounds of the objection.

Facts.

Jarvis sued Ford Motor Co. (Ford) under strict liability and negligence claims. Jarvis submitted instructions for the jury to be instructed on both strict liability and negligence theories, while Ford argued that the jury should only be instructed on one of the theories. The jury was told that Ford could be charged for either negligence, strict liability, or both charges. The jury held Ford liable for the negligence charge. Ford moved for post-judgment relief because the charges were inconsistent, and the court granted Ford judgment as a matter of law. Jarvis appealed.

Issue.

Whether a party waives the right to objection if the party fails to object, state the matter they are objecting to, and the grounds of the objection?

Held.

Yes. The JNOV is vacated and the jury verdict is reinstated. The district court failed to hold Ford accountable to the FRCP. When Ford failed to object to the jury instruction or the verdict sheet, Ford could be found liable under either theory.

Discussion.

Under Federal Rule of Civil Procedure 51, a party waives the right to objection if the party fails to object, state the matter they are objecting to, and the grounds of the objection. This allows the judge to be notified of the claim and to give the jury proper instructions.