West v. Goodyear Tire & Rubber Co.

Ronald West and his wife (plaintiffs) sued tire manufacturer Goodyear Tire & Rubber Co. (Goodyear) and rim manufacturer The Budd Company (Budd) (defendants) after a tire mounted on a mismatched rim exploded, injuring West. West owned an auto-body shop but also did tire and rim work. A customer brought in two 16-inch tires that West inadvertently mounted on 16.5-inch rims. The first tire inflated smoothly without incident, and the second exploded. West retained an attorney whose investigator retained the remnants of the exploded tire and the first tire, which stayed fully inflated. Before bringing suit, West’s lawyer sent the tires to a law firm that specialized in tire-explosion cases, which photographed then deflated the first tire. After discovery began, Goodyear and Budd asked to inspect West’s shop, especially his tire-mounting machine and compressor. However, the month before the scheduled inspection, West sold both pieces of equipment. Goodyear and Budd eventually found the equipment, but it had been left outside and deteriorated. Budd moved to dismiss based on spoliation, while Goodyear moved to exclude the spoliated evidence but not for dismissal, arguing their defenses depended on the spoliated evidence showing West’s equipment malfunctioned such that he overinflated both tires. The judge dismissed the complaint entirely based on spoliation. In the interim, West died, and his wife was substituted on his behalf.