## Facts

- William W. Steil, president of Production Tool Corporation, piloted a Beech Baron 58P from New Orleans to Milwaukee on January 8, 1978, with three passengers.
- Before departure, Steil received weather information indicating moderate to severe turbulence at higher altitudes and icing conditions along parts of the route.
- During the climb, Steil reported beginning to pick up ice; the aircraft later crashed near Tylertown, Mississippi, killing all aboard.
- Plaintiffs (Steil’s estate and the aircraft owner) sued the manufacturer, alleging negligence, strict liability, and failure to warn, asserting an elevator-system design defect that could jam in icing and cause loss of pitch control.
- Beech denied defect and attributed the crash to pilot error, including spatial disorientation and loss of control in adverse weather.
- At trial, plaintiffs sought to introduce evidence of a later crash involving a similar Baron 58P in icing conditions, plus additional accidents and certain government reports to support defect, notice, and warning theories.
- The jury returned a verdict for Beech; the district court entered judgment and denied a new trial. Plaintiffs appealed, challenging evidentiary rulings and asserting prejudice under harmless-error principles.

## Issues

1. Whether the district court abused its discretion by excluding evidence of another Baron 58P crash and other accidents for lack of “substantial similarity” and under Federal Rule of Evidence 403.
2. Whether the district court erred by excluding certain government reports and related materials offered to prove defect, notice, and failure to warn.
3. Whether any evidentiary errors, individually or cumulatively, affected substantial rights and required a new trial under Federal Rule of Civil Procedure 61.

## Decision

- The Seventh Circuit affirmed the judgment for Beech.
- The court held the district court acted within its discretion in excluding other-accident evidence because plaintiffs did not establish substantial similarity and the court reasonably found a risk of confusion and unfair prejudice under Rule 403.
- The court upheld exclusion of government reports and related materials where plaintiffs did not lay an adequate foundation showing reliability and relevance to the aircraft and circumstances at issue.
- Even assuming arguable error, the court concluded any error was harmless because plaintiffs were able to present extensive evidence and the challenged rulings did not affect the trial’s fairness or outcome.

## Legal Principles

- Evidence of other accidents offered to prove defect, dangerousness, or causation in a products-liability case generally requires a showing of substantial similarity in conditions and circumstances.
- Trial courts have broad discretion under Federal Rule of Evidence 403 to exclude otherwise relevant evidence when probative value is outweighed by risks of unfair prejudice, confusion, misleading the jury, or undue delay; appellate review is deferential.
- Under Federal Rule of Civil Procedure 61, a new trial is not warranted for evidentiary error unless the error affects substantial rights; the reviewing court assesses prejudice in context, including the record as a whole and cumulative effect.

## Conclusion

The Seventh Circuit left intact a defense verdict in an aircraft products-liability trial, holding that the district court permissibly excluded other-accident and government-report evidence for inadequate similarity, foundation, and Rule 403 concerns, and that any claimed evidentiary mistakes did not warrant a new trial because they did not affect substantial rights.


Nachtsheim v. Beech Aircraft Corp., 847 F.2d 1261 (7th Cir. 1988)