Rozier v. Ford Motor Co

Brief Fact Summary.

Wife sues Ford for her husband’s death that occurred during a car accident. Plaintiff wife files a FRCP 60(b)(3) motion for a new trial after the jury finds in the Defendant’s favor because a document she requested during discovery was not produced.

Synopsis of Rule of Law.

If a party fails to disclose a document requested during discovery, thereby preventing the opposing party from fully and fairly presenting his case, then the harmed party is entitled to a new trial.

Facts.

William Rozier was killed when his Ford Galaxie 500 was hit from behind and his fuel tank exploded. Plaintiff Martha Rozier, decedent’s wife, sued Defendant Ford, the manufacturer of the automobile, alleging Defendant Ford was negligent in designing the car’s fuel tank. The jury found for Defendant Ford during trial. Plaintiff Rozier filed a FRCP 60(b)(3) motion for a new trial alleging that Defendant Ford failed to disclose a relevant document that she requested in discovery. The document was titled “Confidential Cost Engineering Report that compared the cost of labor and parts of two different gas tank redesigns on full-size Ford cars, like the one Mr. Rozier was driving when he died. The document was found by defendant Ford’s counsel a week before trial but was never produced.

Issue.

If a party fails to disclose a document requested during discovery, thereby preventing the opposing party from fully and fairly presenting their case, is the party that is harmed entitled to a new trial?

Held.

Yes, If a party fails to disclose a document requested during discovery, thereby preventing the opposing party from fully and fairly presenting their case, the party that is harmed is entitled to a new trial. The district court abused its discretion in denying plaintiff’s FRCP 60(b)(3) motion and the new trial that was required.

Discussion.

1. Under FRCP 60(b)(3) the court may relieve a party from a final judgement because of fraud, misrepresentation, or misconduct.
2. Plaintiff Rozier requested all documents relating to cost-benefit analysis for fuel tanks in full-size sedans. This included the Confidential Cost Engineering Report, yet Defendant Ford failed to produce it despite their counsel learning of its existence a week before trial.
3. Plaintiff’s attorney, without the Confidential Cost Engineering Report, allows one of the negligence charges to be removed because he did not think he could prove the charge. Defendant’s actions shifted the outcome of the case through its fraud by not producing the report.
4. Because Plaintiff Rozier was denied her right to fully and fairly present her case, the holding below is reversed and a new trial is ordered.