McFarland v. Bruno Mach. Corp.

McFarland v. Bruno Mach. Corp.

Evid.R. 407, which bars admission of subsequent remedial measures to prove negligence or culpable conduct, does not apply to products liability claims premised upon strict liability in tort; therefore evidence of post-accident design changes or guards is admissible and the court of appeals' exclusion was erroneous.

Source-derived case information.

Citation
1994 Ohio 62; 68 Ohio St. 3d 305
Parties
Appellant: Lester McFarland; Appellant: Cynthia McFarland; Appellee: Bruno Machinery Corporation; Amicus Curiae (urging Reversal): Ohio Academy of Trial Lawyers; Amicus Curiae (urging Affirmance): Ohio Association of Civil Trial Attorneys
Court
Ohio Supreme Court
Jurisdiction
United States
Judgment Date
15 February 1994
Case Number
1992-2236
Procedural Posture
Torts Products Liability (strict Liability) / Appeal to Supreme Court of Ohio From Court of Appeals (warren County) Decision; Judgment Reversed and Remanded
Outcome
Judgment of the court of appeals reversed; cause remanded to trial court for further proceedings consistent with opinion.
Legal Topics
Strict Liability, Subsequent Remedial Measures, Evid.r. 407, Admissibility of Evidence, Design Defect
Source Language
english
Tort Products Liability Evidence Law Strict Liability Subsequent Remedial Measures Evid.r. 407 Admissibility of Evidence Design Defect

Source-derived case record

Summary, issues, holding and outcome

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Parties

Lester McFarland

Appellant

Cynthia McFarland

Appellant

Bruno Machinery Corporation

Appellee

Ohio Academy of Trial Lawyers

Amicus Curiae (urging Reversal)

Ohio Association of Civil Trial Attorneys

Amicus Curiae (urging Affirmance)

Procedural Posture

Torts Products Liability (strict Liability) / Appeal to Supreme Court of Ohio From Court of Appeals (warren County) Decision; Judgment Reversed and Remanded

Legal Issues

  1. 1 Whether Evid.R. 407 applies to products liability claims premised on strict liability
  2. 2 Whether evidence of post-accident design changes by manufacturer or post-accident guards by employer is admissible to prove a design defect
  3. 3 Balancing probative value of remedial measures against prejudice and public policy considerations

Ratio Decidendi

Evid.R. 407, which bars admission of subsequent remedial measures to prove negligence or culpable conduct, does not apply to products liability claims premised upon strict liability in tort; therefore evidence of post-accident design changes or guards is admissible and the court of appeals' exclusion was erroneous.

Court Disposition

Judgment of the court of appeals reversed; cause remanded to trial court for further proceedings consistent with opinion.

Orders

  • Judgment of Court of Appeals reversed
  • Cause remanded to trial court for further proceedings consistent with this opinion