## Facts

- Arthur LaPlante, a Rhode Island domiciliary stationed in Colorado, rode a friend’s Honda three-wheel ATV downhill on Pike’s Peak in March 1989.
- LaPlante, a first-time ATV rider, failed to negotiate a turn, went over an embankment, and suffered catastrophic injuries resulting in quadriplegia.
- He alleged the ATV had a “plowing” tendency (continuing straight despite steering input) and that Honda failed to provide adequate warnings despite knowledge of the risk.
- Honda denied defect or knowledge requiring additional warnings.
- LaPlante sued Honda in federal court in Rhode Island asserting negligent failure to warn, strict-liability design defect, breach of warranty, and punitive damages.
- The district court applied Rhode Island law to compensatory damages, removed punitive damages from the jury via judgment as a matter of law, admitted evidence of Honda’s net ATV profits with a limiting instruction, and declined to instruct on Rhode Island’s “subsequent alteration” defense.
- The jury found Honda liable on failure-to-warn negligence and strict-liability design defect, awarded compensatory damages, and reduced the total by 15% for comparative negligence.

## Issues

1. Whether Rhode Island or Colorado law governed compensatory damages, including Colorado’s non-economic damages cap and Rhode Island’s prejudgment interest statute.
2. Whether the failure to instruct the jury on Rhode Island’s statutory subsequent-alteration defense required reversal and a new trial on liability.
3. Whether the district court properly granted judgment as a matter of law for Honda on punitive damages under Rhode Island’s heightened standard.
4. Whether admitting evidence of Honda’s ATV profits (with limiting instructions) was erroneous and prejudicial.

## Decision

- The court held Rhode Island law properly governed compensatory damages under Rhode Island’s interest-weighing choice-of-law approach.
- The court vacated the liability judgment and remanded for a new trial on liability because the district court’s refusal to instruct on the subsequent-alteration defense was reversible error.
- The court affirmed judgment as a matter of law for Honda on punitive damages because the evidence did not satisfy Rhode Island’s requirement of willful, malicious, or criminal-level misconduct.
- Other challenged rulings, including profits evidence, were addressed in light of the remand; the instruction error was the central basis for vacatur.

## Legal Principles

- Under Rhode Island’s interest-weighing approach, the governing law is that of the state with the most significant relationship to the parties and the occurrence, and whose policies are most advanced by application of its law.
- A forum may apply its compensatory-damages regime when the injured plaintiff is a forum domiciliary and the forum’s compensation and deterrence interests outweigh another state’s damages-limiting policy.
- Rhode Island’s prejudgment interest statute may be applied to the full verdict, including future damages, to compensate for delay and encourage settlement.
- Under Rhode Island products-liability law, a defendant is entitled to a jury instruction on the statutory subsequent-alteration defense when evidence supports that post-sale alteration or modification substantially caused the injury.
- Rhode Island punitive damages require proof of conduct amounting to willfulness, recklessness, or wickedness comparable to criminality; negligence or gross negligence is insufficient.

## Conclusion

The First Circuit upheld applying Rhode Island law to compensatory damages and affirmed dismissal of punitive damages, but it vacated the liability verdict and ordered a new liability trial because Honda was entitled to a jury instruction on the statutory subsequent-alteration defense supported by the evidence.


LaPlante v. Am. Honda Motor Co., 27 F.3d 731 (1st Cir. 1994)