Campbell v. Coleman Co.

Janet M. Campbell, as next friend of minors July A. Campbell and James E. Campbell (plaintiffs), sued The Coleman Company (defendant) for damages the children sustained when a Coleman lantern exploded. Causation was the central issue. Campbell's theory of causation was strict liability, based on a manufacturing defect in the lantern that caused the explosion. Coleman's theory was that the lantern caught fire after Johnnie Lee Hayes filled the lantern with gasoline. Hayes threw the burning lantern outside, where it hit the children. In his pretrial deposition, Hayes testified that he saw the children on fire and the lantern shooting flames, so he threw the lantern off the porch. He also testified he had made no contrary statements about how the children were injured. Both parties tried but failed to subpoena and locate Hayes to testify at trial. Coleman proffered witness testimony that Hayes made several out-of-court statements implicating his responsibility for the explosion. Campbell objected and made it known that Hayes' deposition was available, but the judge overruled the objection and admitted Hayes' out-of-court statements under the Federal Rule of Evidence 804(b)(3) hearsay exception for statements against interest. The jury ruled for Coleman. Campbell appealed to the United States Court of Appeals for the Eighth Circuit, arguing the judge erred in admitting the out-of-court statements.