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Norton v. Snapper Power Equipment

United States Court of Appeals for the Eleventh Circuit · 1987 · Civil Procedure

Civil Proceduredirected verdictJMOLproducts liabilitylawnmowerRule 50(b)judgment notwithstanding the verdictdirected verdict

Facts

Norton, who worked in the commercial lawn mowing business, was injured while using a Snapper riding mower near a creek. He testified that after driving up an incline, the mower began sliding backward toward the creek; he applied the brakes and kept both hands on the handlebars until impact, but during the crash his hand was caught in the blades and four fingers were amputated. Norton claimed the mower was defective because it lacked a dead man control or automatic blade stop device. At trial, Norton presented expert testimony that effective blade-stopping technology existed before 1981 and could stop blades much faster than the 1981 mower, while Snapper offered contrary expert testimony.

Issue

Whether the district court properly entered judgment notwithstanding the verdict for Snapper on Norton's strict liability claim. More specifically, whether the trial court could do so without an express post-verdict motion or express reservation, and whether the evidence was sufficient for a reasonable jury to find both defect and causation.

Rule

A judgment notwithstanding the verdict is governed by the same standard as a directed verdict: viewing the evidence in the light most favorable to the nonmoving party, the court may grant it only when the evidence points so strongly in favor of the movant that reasonable people could not reach a contrary verdict, and the court may not reweigh the evidence. Under Rule 50(b), when a directed-verdict motion made at the close of all the evidence is denied or not granted, the action is deemed submitted to the jury subject to later determination of the legal questions raised by that motion, so an express reservation is unnecessary. In Florida strict liability design-defect cases, state-of-the-art feasibility is a relevant factor in deciding whether a product is unreasonably dangerous, but it is only one factor, and causation may be proved by reasonable circumstantial inferences rather than speculation.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Tampa, Elena Ruiz sued Gulf Ridge Tools, Inc. for strict liability, alleging a floor scrubber was defectively designed. At the close of all the evidence, Gulf Ridge orally moved for a directed verdict on defect and causation; the judge neither expressly granted nor expressly reserved ruling, sent the case to the jury, and the jury returned a verdict for Ruiz. Minutes later, without asking for a written post-verdict motion, the judge entered judgment for Gulf Ridge on those same two issues.

Was the judge procedurally permitted to enter judgment notwithstanding the verdict on those issues?

Explanation. Under the majority opinion, Rule 50(b) provides that when a directed-verdict motion made at the close of all the evidence is denied or not granted, the action is deemed submitted to the jury subject to later determination of the legal questions raised by that motion. So no express reservation is necessary, and the trial court may act on the issues already raised without insisting on empty formalities.