## Facts

- Brian and Kendra Carpenter bought a new 1986 Chrysler LeBaron from a Chrysler-authorized dealer (CPW) in August 1986 after requesting a reliable vehicle for Kendra.
- Before sale, CPW discovered a power-steering leak and received a recall notice and kit to correct a wiring-harness defect causing intermittent no-start, but the recall repair was not completed before delivery.
- The car would not start for the intended test drive; the salesperson attributed the problem to a dead battery, and Brian Carpenter signed the contract without a test drive and purchased an extended service contract.
- CPW issued an inspection certificate listing 16 miles on the odometer and stating the vehicle was in good mechanical order.
- The Carpenters later learned the car had been driven with the odometer disconnected before their purchase.
- Soon after delivery, the vehicle exhibited repeated and serious defects (including power steering, ignition/no-start, oil leaks, electronic display issues, and transmission problems).
- CPW performed multiple repair attempts (including replacement of steering gear, torque converter twice, speed sensor switch, and the transaxle) but did not repair the wiring-harness recall defect.
- After continuing failures and repeated repair visits, Carpenter sought replacement and contacted the installment-contract assignee.

## Issues

1. Whether the trial court abused its discretion by granting CPW a new trial based on asserted instructional error, evidentiary insufficiency, and punitive-damages concerns.
2. Whether the trial court abused its discretion by granting Chrysler a new trial on the ground that the verdict was against the weight of the evidence.
3. Whether the Carpenters presented submissible claims such that the trial court correctly denied Chrysler’s and CPW’s motions for judgment notwithstanding the verdict (JNOV).

## Decision

- The appellate court reversed the order granting CPW a new trial, holding the trial court abused its discretion as to CPW.
- The appellate court affirmed the order granting Chrysler a new trial, deferring to the trial court’s discretion on weight-of-the-evidence grounds.
- The appellate court affirmed the denial of JNOV for both Chrysler and CPW, holding the Carpenters made submissible cases on the claims submitted to the jury.
- As a result, the jury’s verdicts against CPW were reinstated, while Chrysler received a new trial.

## Legal Principles

- A trial court has broad discretion to grant a new trial when it concludes the verdict is against the weight of the evidence; appellate review is highly deferential, particularly when the new trial benefits a defendant.
- Appellate courts may reverse a new-trial order when it rests on legal error (including incorrect conclusions about submissibility, instructions, or the availability of punitive damages), rather than on discretionary weight-of-the-evidence assessment.
- In reviewing submissibility and JNOV, courts view evidence and reasonable inferences in the light most favorable to the verdict and disregard contrary evidence.
- Evidence that a seller knew of significant pre-sale defects or recall conditions, failed to disclose them, and represented the vehicle as reliable and in good condition can support submission of fraud-based claims and support punitive damages.

## Conclusion

The court drew a line between discretionary weight-of-the-evidence new-trial orders (affirmed for Chrysler) and new-trial orders grounded in legal error (reversed for CPW), while also holding that the Carpenters presented sufficient evidence to submit their claims to the jury and to defeat JNOV for both defendants.


Carpenter v. Chrysler Corp., 853 S.W.2d 346 (Mo. Ct. App. 1993)