## Facts

- Henry Lecy, his wife Karen Lecy, and Marco and Pamela Bacich chartered a Bayliner motor yacht for a pleasure trip.
- While the vessel was at sea, conditions became turbulent.
- Henry Lecy fell against a port-side cabin door; the door opened and both the door and Lecy went overboard.
- Henry Lecy drowned despite rescue efforts.
- Karen Lecy sued Bayliner Marine Corp. for wrongful death and later added a claim for negligent infliction of emotional distress (NIED).
- The Baciches filed a separate action against Bayliner for NIED; the trial court consolidated the cases.
- Plaintiffs alleged the yacht’s cabin door system (including its latching/closure design) was unsafe and allowed the door to open in foreseeable sea conditions, resulting in Lecy’s fall overboard.
- At trial, the court used a special-verdict form with interrogatories addressing both strict products liability (design and construction) and negligence (including negligent design).
- Bayliner objected to the verdict form, arguing that if the jury found the door system was not “unreasonably dangerous” for strict-liability design defect, then the jury should not be permitted to reach negligent design on the same design and proof.
- The jury found the door system was not unreasonably dangerous in design or construction (no strict liability), but also found Bayliner negligently designed the door system and that this negligence proximately caused Henry Lecy’s death and the plaintiffs’ emotional distress.
- Bayliner moved for judgment notwithstanding the verdict (JNOV); the trial court denied the motion and entered judgment on the negligence verdict.

## Issues

1. Under the admiralty-law standards and the instructions given, could the jury find the door system not unreasonably dangerous for strict-liability design defect and still find Bayliner negligent in design based on the same design features and evidence?
2. Did the trial court commit reversible error by submitting a special verdict form that allowed legally inconsistent findings (no strict-liability defect but negligent design), and by denying Bayliner’s post-trial relief?

## Decision

- The Court of Appeals reversed the judgment against Bayliner and remanded for a new trial.
- On this record, there was no practical difference between the strict-liability design-defect inquiry and the negligent-design inquiry as submitted to the jury.
- The jury’s finding that the door system was not defectively designed (not unreasonably dangerous) established, as a matter of law in this case, that Bayliner was not negligent in designing the same door system.
- The special verdict form improperly allowed the jury to reach negligent design after rejecting strict-liability design defect, producing legally incompatible answers that could not support the judgment.

## Legal Principles

- In maritime product cases tried under a risk–utility type evaluation of design, strict-liability design defect and negligent design may merge into the same functional question, depending on the instructions and proof.
- When the jury, under the given instructions, finds a product’s design is not unreasonably dangerous (no design defect), a negligent-design verdict on the same alleged design flaw and evidence cannot stand.
- A special verdict form that permits the jury to return answers that are legally incompatible on design defect and negligent design is erroneous; the resulting judgment must be set aside when the answers cannot be reconciled under the governing law and instructions.
- Admiralty law supplies the controlling rules for maritime injury claims, and those rules govern how overlapping negligence and strict-liability design theories are treated in the case.

## Conclusion

Because the case was tried so that strict-liability design defect and negligent design turned on the same design-risk analysis, the jury’s no-defect finding foreclosed a negligent-design verdict; the trial court’s verdict form allowed inconsistent findings, so the appellate court reversed and remanded for a new trial.


Lecy v. Bayliner Marine Corp., 973 P.2d 1110 (1999)