## Facts

- Arlitha J. Henderson bought an electric blanket manufactured by Sunbeam Corporation and sold by Sears, Roebuck and Company.
- About two years later, a fire in Henderson’s bedroom caused property damage.
- The parties stipulated the fire originated from an electrical source in the bedroom, specifically on or near the bed.
- Henderson claimed a defect in the blanket’s electrical system caused the fire and existed when the product left defendants’ hands.
- Henderson presented expert testimony from a fire-origin investigator who examined the scene and concluded the blanket started the fire.
- Henderson also presented an electrical-malfunction expert who agreed the blanket was the source and identified a defective electrical connection as the causal mechanism, though the precise connection could not be pinpointed because of fire damage.
- Defendants presented experts who attributed the fire to the bed’s vibrator feature, disputing blanket defect and causation.
- A jury found defendants liable for Henderson’s property loss.
- Defendants sought judgment as a matter of law (Rule 50) for evidentiary insufficiency and, alternatively, a new trial (Rule 59) as against the weight of the evidence; the district court denied both motions.

## Issues

1. Whether the district court erred in denying defendants’ Rule 50 motion because the evidence of defect and causation, largely circumstantial and expert-based, was legally insufficient.
2. Whether the district court abused its discretion in denying defendants’ Rule 59 motion because the verdict was clearly, decidedly, or overwhelmingly against the weight of the evidence.

## Decision

- The court of appeals affirmed the judgment for Henderson.
- The court held the evidence permitted reasonable inferences supporting the jury’s finding that a defect in the blanket caused the fire and existed when the product left defendants’ control.
- The court held the district court properly denied Rule 50 because the evidence did not “point but one way” in defendants’ favor given competing expert accounts.
- The court held the district court did not abuse its discretion in denying a new trial because the verdict was not clearly, decidedly, or overwhelmingly against the weight of the evidence.

## Legal Principles

- Under Oklahoma products-liability law, a plaintiff must show: (1) a defective product caused the injury or property damage; (2) the defect existed when the product left the manufacturer or seller; and (3) the defect made the product unreasonably dangerous.
- Circumstantial evidence and expert opinion testimony may establish defect and causation in products-liability cases; an objection that proof is indirect typically concerns weight, not admissibility or legal sufficiency.
- Oklahoma law permits drawing reasonable inferences from inferential premises; “inference upon inference” is not categorically barred.
- Rule 50 review requires judgment as a matter of law only when the evidence allows no reasonable inferences supporting the verdict.
- Rule 59 denial is reviewed for abuse of discretion; a verdict will not be set aside unless it is clearly, decidedly, or overwhelmingly against the weight of the evidence.

## Conclusion

The court affirmed a jury’s products-liability verdict where the plaintiff’s experts and stipulated fire origin supported reasonable inferences that a defective electric blanket caused the fire, and the defendants’ alternative expert theory created a credibility dispute for the jury rather than a basis for judgment as a matter of law or a new trial.


Henderson v. Sunbeam Corp., 46 F.3d 1151 (10th Cir. 1995)