## Facts

- In 2006, a 1996 Toyota Camry driven by Koua Fong Lee rear-ended a stopped vehicle at high speed near an exit ramp and stoplight, causing multiple deaths and serious injuries.
- Lee and passengers testified that he attempted to brake, but the vehicle did not slow and he reported the brakes were not working.
- Lee was convicted in state court of criminal vehicular homicide; the conviction was later vacated and the state declined retrial.
- Injured parties and representatives of decedents filed consolidated federal products-liability actions alleging a design defect causing unintended acceleration; Toyota contended the crash resulted from pedal misapplication (driver error).
- Plaintiffs relied principally on expert testimony that the accelerator-throttle and cruise-control design could produce unintended acceleration, including during braking.
- After trial, the jury allocated fault 60% to Toyota and 40% to Lee and awarded roughly $14 million in total damages (before fault allocation).
- The district court admitted a limited set of evidence concerning other similar incidents (OSIs), admitted the plaintiffs’ expert under Rule 702, awarded prejudgment interest on lump-sum awards combining past and future damages, and reduced one wrongful-death recovery based on a prior settlement involving Lee and his insurers.

## Issues

1. Whether the district court abused its discretion by admitting OSI evidence without sufficient substantial similarity and in violation of Rule 403.
2. Whether the district court abused its discretion under Rule 702 and Daubert by admitting plaintiffs’ expert testimony on defect and causation.
3. Whether Toyota was entitled to judgment as a matter of law because evidence of design defect and proximate cause was insufficient under Minnesota law.
4. Whether Minnesota prejudgment-interest law permits interest on a lump-sum verdict that combines past and future damages when the components cannot be separated, and whether a wrongful-death award required a setoff for a prior settlement.

## Decision

- The court affirmed admission of a limited number of OSIs, holding the district court acted within its discretion in finding substantial similarity and managing Rule 403 concerns.
- The court affirmed admission of the plaintiffs’ expert testimony, concluding the methodology and supporting materials satisfied Rule 702 and that criticisms largely went to weight.
- The court affirmed denial of Toyota’s JMOL motion, holding a reasonable jury could find a design defect and proximate causation based on expert, lay, and OSI evidence.
- The court reversed the prejudgment-interest award on lump-sum damages that mixed past and future losses where the record made separation impossible, and remanded.
- The court reversed the reduction of the wrongful-death recovery based on the prior settlement, holding no impermissible double recovery where different beneficiaries were involved.

## Legal Principles

- OSI evidence in products-liability cases may be admitted when incidents are substantially similar in product design, alleged defect, and circumstances, subject to trial-court discretion and Rule 403 balancing.
- Under Rule 702 and Daubert, reliability is assessed by methodology and supporting basis; alleged weaknesses commonly affect weight for the jury rather than admissibility when the approach is sufficiently grounded.
- On JMOL, the evidence is viewed in the light most favorable to the verdict; competing causation theories and credibility conflicts are for the jury if a reasonable evidentiary basis supports the verdict.
- Under Minnesota law as predicted by the Eighth Circuit, prejudgment interest is not awarded on a lump-sum judgment combining interest-eligible past damages and non-eligible future damages when the components cannot be differentiated.
- A settlement setoff is not required where the earlier settlement and the later award benefit different plaintiffs/beneficiaries and therefore do not constitute double recovery.

## Conclusion

The Eighth Circuit largely upheld the jury’s product-defect verdict and the district court’s evidentiary rulings on similar-incident and expert testimony, but it vacated prejudgment interest awarded on unsegregated lump-sum damages that included future losses and reinstated a wrongful-death award that had been improperly reduced by a prior settlement involving different beneficiaries.


Adams v. Toyota Motor Corp., 867 F.3d 903 (8th Cir. 2017)