Wilson v. Vermont Castings, Inc.

Brief Fact Summary.

The jury entered a verdict in Defendant’s favor in this case, in which Plaintiffs sought to recover  damages after one of the Plaintiffs sustained injuries after using a woodburning stove. The jury found that the stove was defective, but that the defect was not a substantial factor in causing the injuries alleged. After the trial, Plaintiffs’ counsel learned that one of the jurors, who also owned one of the stoves Defendant sold, told the other jurors that she, like Plaintiffs, had to leave the stove door open to start the fire. She also reviewed her stove’s manual regarding warnings, and told the other jurors about what she learned. Plaintiffs moved for a new trial, alleging juror misconduct.

Synopsis of Rule of Law.

Jurors may not impeach their own verdicts and are not competent to testify about their thought processes or deliberations, except that a juror may testify about whether extraneous prejudicial information, or outside influence, was brought to the jury’s attention or brought to bear on any juror.

Facts.

Plaintiffs’ sustained injuries while using a woodburning stove sold by Defendant.  The complaint alleged strict liability and negligence and asserted claims for loss of consortium and punitive damages. Trial proceeded on the strict liability claim only, and the jury entered a verdict in Defendant’s favor. The jury found that the stove was defective, but that the defect was not a substantial factor in causing Plaintiffs’ injury. During post-trial conversations with jurors, Plaintiffs’ counsel learned that one of the jurors also owned one of the stoves Defendant sold. That juror told the other jurors that she, like Plaintiffs, found it necessary to leave the stove door open to start the fire. The juror also reviewed her stove’s manual regarding warnings, and told the other jurors about what she learned. Plaintiffs moved for a new trial, alleging juror misconduct.

Issue.

Was a new trial necessary in this case due to juror misconduct?

Held.

No, a new trial was not necessary.

Discussion.

Although Federal Rule of Evidence 606(b) prohibits inquiry into the jury’s deliberative process, a juror may testify about whether extraneous prejudicial information or outside influence was brought to the jurors’ attention or brought to bear on any juror. Here, with regard to the juror’s information about leaving the door open when lighting her own stove, that information was simply a matter of that juror drawing from her own life experience, and it would be improper for the court to inquire further. The information about warnings contained in the manual was different; the juror did this on her own, outside of the courtroom, for the purpose of testing or evaluating the evidence. Nevertheless, this information did not go to causation, which was the only liability issue on which Plaintiffs did not prevail, and Plaintiffs did not suffer any prejudice, even if the information from the manual was considered, because Plaintiffs had prevailed on the issue of product defect.