LaPlante v. American Honda Motor Co., Inc.

27 F.3d 731 (1994)

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LaPlante v. American Honda Motor Co., Inc.

United States Court of Appeals for the First Circuit
27 F.3d 731 (1994)

Facts

Arthur LaPlante (plaintiff) was paralyzed while riding an all-terrain vehicle (ATV) on Pike’s Peak in Colorado. LaPlante was enlisted and stationed at a nearby army base, but he had remained a domiciliary of his native Rhode Island during his service, and he returned to Rhode Island after his accident. The ATV was designed and manufactured by Honda (defendant) in Japan. LaPlante sued Honda in Rhode Island federal district court, asserting causes of action including a claim for negligent failure to warn and strict liability for a design defect. To support the failure-to-warn claim, LaPlante asserted that Honda knew that its ATVs would continue moving in a straight line even if the handlebars were turned, a problem known as plowing. Honda asserted that it was unaware of the plowing problem. The district court applied Rhode Island law, which had no cap on pain-and-suffering damages, rather than Colorado law, which had a cap that the Colorado legislature had enacted to increase the affordability and availability of insurance. The district court also allowed LaPlante to introduce into evidence Honda’s answers to certain interrogatories, which revealed Honda’s large net profits from ATV sales. LaPlante intended this evidence to show that Honda failed to warn ATV buyers about the plowing problem because of greed. The trial judge told the jury that the evidence of profits was introduced to help the jurors reach conclusions about Honda’s credibility, not to encourage the jury to take money from Honda merely because ATV sales were profitable. Honda objected to the introduction of this evidence. The jury ultimately found Honda liable on the failure-to-warn and strict-liability claims and awarded LaPlante $2,652,000 in medical expenses and lost wages and $6,000,000 for physical injuries and pain and suffering, reducing the award by 15 percent for LaPlante’s comparative negligence. Honda appealed to challenge, among other things, (1) the district court's decision to apply Rhode Island law and (2) the district court's decision to allow evidence of Honda's profitability from ATV sales.

Rule of Law

Issue

Holding and Reasoning (Bownes, J.)

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