## Facts

- David Binakonsky was driving a Ford-manufactured van when he drove into a tree and died in a fire that occurred after the impact.
- Binakonsky’s family sued Ford Motor Company, alleging a product defect caused the van’s fuel line to rupture and start the fire that ultimately killed him.
- The family did not claim Ford caused the initial collision; instead, they advanced a crashworthiness theory that a defect led to the post-impact fire and resulting death.
- The family planned to present an expert witness to prove the alleged defect and to link the defect to the fire-related death.
- Before the expert testified, the district court excluded certain exhibits the expert planned to rely on.
- After those rulings, the family’s counsel told the court the exclusions removed the factual basis for the expert’s opinion.
- The expert did not testify at trial.
- Ford moved for judgment as a matter of law, arguing the family lacked sufficient evidence for a reasonable jury to find defect and causation.
- The district court granted Ford’s motion, and the family appealed.

## Issues

1. Whether the district court abused its discretion by excluding exhibits that the family’s expert intended to rely on as support for opinions about defect and fire causation.
2. Whether, in the absence of the excluded materials and without the expert’s testimony, the district court properly granted Ford judgment as a matter of law for lack of sufficient evidence on defect and causation.

## Decision

- The Fourth Circuit affirmed the district court’s judgment as a matter of law for Ford.
- The court held the district court did not abuse its discretion in excluding the exhibits the expert planned to use.
- The court held that, without admissible proof supporting the expert’s opinions and with the expert not testifying, the family lacked legally sufficient evidence to submit the defect and causation questions to a jury.

## Legal Principles

- Appellate review of evidentiary rulings is deferential; a trial court’s decision to admit or exclude evidence is reviewed for abuse of discretion.
- In technically complex product-defect and crashworthiness cases, a plaintiff generally must present admissible expert testimony to establish (1) a defect and (2) a causal link between the defect and the post-impact injury or death.
- If a plaintiff lacks legally sufficient evidence on essential elements of the claim after the court’s evidentiary rulings, judgment as a matter of law under Federal Rule of Civil Procedure 50 is proper.
- When an expert’s opinion depends on excluded supporting materials and the expert does not testify, the remaining record may be insufficient to permit a reasonable jury to find for the plaintiff on defect and causation.

## Conclusion

The Fourth Circuit affirmed judgment for Ford because the district court permissibly excluded exhibits that formed the basis for the family’s planned expert testimony, the expert therefore did not testify, and the resulting trial record lacked sufficient evidence for a jury to find a defect in the van caused the post-impact fire that killed Binakonsky.


Binakonsky v. Ford Motor Company, 4 Fed. App’x 161 (2001)