## Facts

- Richard Crossley, driving a 1987 Chevrolet S-10 Blazer, crashed on a banked, curved two-lane interstate connector ramp near Ontario, California, suffering catastrophic injuries.
- Eyewitnesses and reconstruction evidence placed Crossley’s speed at about 70 mph in a 55 mph zone while passing vehicles on the curve.
- The vehicle’s tires were in poor condition: mismatched size/brand, worn, and repaired with nails/screws/plugs; eyewitnesses noted the left rear tire was low on air.
- One eyewitness observed the left rear tire begin to buckle, followed by loss of control and fishtailing across lanes; the Blazer rotated and left the ramp, traveling roughly 40–50 feet before rolling.
- After the crash, an axle shaft was found fractured; the central dispute was whether the axle failed before the crash (causing loss of control) or fractured during the crash.
- Crossley asserted a manufacturing defect made the axle brittle, causing it to crack and fail before the crash; GM argued the crash resulted from speeding and bad tires and that crash forces broke the axle.
- The jury returned a special verdict finding a manufacturing defect (brittle axle) but finding the defect did not cause the accident; it found the accident caused the axle to break.
- The district court denied Crossley’s motion for a new trial; Crossley appealed.

## Issues

1. Whether the special verdict was fatally inconsistent because it found a manufacturing defect but found the defect did not cause the accident.
2. Whether sufficient evidence supported the jury’s finding that the defect was not a proximate cause under California products-liability law.
3. Whether the district court abused its discretion in denying a new trial based on claimed inconsistency and weight of the evidence.

## Decision

- The Seventh Circuit affirmed the judgment for GM and affirmed denial of a new trial.
- The court held the special verdict was reconcilable: the jury could find the axle defective yet conclude it fractured as a result of the crash, not as its cause.
- The court held sufficient evidence supported the jury’s no-causation finding, including testimony about speeding, tire condition, and the absence of observed signs of a pre-impact axle failure.
- The court found no abuse of discretion in denying a new trial because the verdict was not irreconcilably inconsistent and was supported by the evidence.

## Legal Principles

- In California strict products liability, proof of a manufacturing defect is insufficient without proof that the defect was a substantial factor in causing the injury.
- Special verdict answers must be harmonized if a reasonable reading makes them consistent; a verdict should be set aside only when answers are irreconcilable.
- Appellate courts defer to the jury’s resolution of conflicts in eyewitness and expert testimony when the record provides adequate evidentiary support for the verdict.
- A component may be defective yet non-causal where evidence supports that independent factors caused the accident and the defective component failed only under crash forces.

## Conclusion

The court upheld a defense verdict where the jury found a defective axle but reasonably concluded the defect did not cause the crash, emphasizing that causation remains required in strict products liability and that special verdicts and credibility choices by the jury are sustained when supported by the record.


Crossley ex rel. Crossley v. Gen. Motors Corp., 33 F.3d 818 (7th Cir. 1994)