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Wilson v. Vermont Castings, Inc.

United States Court of Appeals for the Third Circuit
170 F.3d 391 (3d Cir. 1999)


Facts

Anne Wilson (plaintiff) owned a Vermont Castings (defendant) woodburning stove. One day, when using the stove, Wilson left a side door on the stove open to help start the fire. While standing near the open door, her dress caught fire, resulting in severe injures. Wilson brought a products liability suit arguing that the stove was defective. Wilson had never read the contents of the stove’s owner manual so the trial court excluded the manual from evidence. During jury deliberations, one of the jurors who owned a Vermont Castings stove told the other jurors of her experience with the stove, including the fact that she often left the side door open and that she would not change her behavior if there was a warning on the stove. The jury found that the stove was defective, but that the defect was not a substantial factor in causing Wilson’s injury. After trial, Wilson’s lawyer spoke with the juror who owned the Vermont Castings stove and learned of the contents of the deliberations. Based on this information, Wilson filed a motion for a new trial, arguing that (1) the juror should not have looked at her own Vermont Castings manual or told the other jurors about its contents and (2) the juror should not have told the other jurors that she would not change her behavior about opening the side door. The district court denied the motion. Wilson appealed.

Rule of Law

Issue

Holding and Reasoning (Magill, S.J.)

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