Adams v. Toyota Motor Corp.

867 F.3d 903 (2017)

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Adams v. Toyota Motor Corp.

United States Court of Appeals, Eighth Circuit
867 F.3d 903 (2017)

  • Written by Rose VanHofwegen, JD
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Facts

Koua Fong Lee (plaintiff) was exiting the freeway in his 1996 Camry when the brakes failed to stop the car. He travelled another 600 feet at some 75 miles an hour and rear-ended a vehicle stopped at the red light. Everyone in Lee’s car survived, but three people in the other car died. Lee was convicted of vehicular homicide and sentenced to eight years in prison. Two years later, Toyota Motor Corp. (defendant) recalled several Camry models (but not Lee’s) because of instances of unintended acceleration. The court waived Lee’s conviction and released him. A relative of the people killed, Jassmine Adams (plaintiff), sued Toyota, claiming a defective acceleration system caused the accident, and Lee joined the suit. Before trial, Toyota moved to exclude evidence of other similar incidents (OSIs) involving unintended acceleration of 1996 Camrys. The trial court, acknowledging the dangers of allowing OSI evidence that confuses the issues or creates undue prejudice, allowed only three witnesses who experienced incidents most similar to Lee’s to testify. All three testified to driving a 1996 Camry with over 100,000 miles that unexpectedly either accelerated or maintained its speed despite stepping off the accelerator. All three testified that the brakes were ineffective or nearly useless in stopping the car, and that it took at least 600 feet to regain control. Two testified that the problem stopped after a mechanic cleaned the throttle body, but none could identify what caused the problem with certainty. The jury entered a verdict for Adams and Lee. Toyota appealed, arguing the trial court should not have admitted the OSI evidence because Adams and Lee did not show that the same defect that caused the OSIs caused Lee’s accident.

Rule of Law

Issue

Holding and Reasoning (Kelley, J.)

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