United States District Court for the Middle District of Pennsylvania
977 F. Supp. 691 (M.D. Pa. 1997)
Vermont Castings (Vermont) (defendant) manufactured and sold wood stoves. Ann Wilson (plaintiff) was injured when her clothes ignited while she was starting a fire in her stove. Wilson and Oliver J. Larmi (plaintiff) sued Vermont for punitive damages and loss of consortium under theories of strict liability and negligence. Only the strict liability claim went to trial. At Vermont’s request, the judge excluded the instruction manual that came with the wood stove from evidence on the ground that it was irrelevant. There was no indication that Wilson had seen the manual. The jury was presented with two questions on the issue of Vermont’s liability: (1) whether the stove was defective and (2) whether the defect proximately caused Wilson’s injuries. The jury concluded that the stove was defective but that the defect did not proximately cause Wilson’s injuries. After trial, Wilson’s attorneys learned that one of the jurors owned a Vermont stove. Further, the juror indicated that during deliberations, she had read the instruction manual that came with the stove and reported back to the rest of the jury about the warnings contained in the manual. The juror also told the other jurors that she had to leave the door to the stove ajar when in use. The plaintiffs moved for a new trial on the ground of juror misconduct.
Rule of Law
Holding and Reasoning (McClure, J.)
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