## Facts

- James Norton operated a Snapper lawnmower in his commercial lawn-mowing business.
- While mowing near a creek, Norton drove up an incline and, as he neared the top, the mower began sliding backward.
- Norton and the mower went into the creek during the backward slide.
- Norton’s hand was severely injured when it came into contact with the mower’s rotating blade.
- Norton sued Snapper Power Equipment (Snapper), asserting negligence, breach of warranty, and strict products liability based on an alleged design defect.
- Norton’s design-defect theory was that the mower was unreasonably dangerous because it lacked an operator-presence (“dead man”) control or other device that would stop the blade when the operator left the seat or lost control.
- At the close of Norton’s case, Snapper moved for a directed verdict; the trial court removed the negligence and warranty claims from the jury but submitted the strict-liability claim.
- The jury returned a verdict for Norton on strict liability, but the trial judge later entered judgment notwithstanding the verdict (JNOV) for Snapper, concluding the evidence could not support a finding that the mower was defective.

## Issues

1. Whether the district court properly entered JNOV after a jury verdict for Norton on strict products liability, on the ground that the evidence was insufficient for a reasonable jury to find the lawnmower defectively designed and unreasonably dangerous.

## Decision

- The Eleventh Circuit reversed the JNOV.
- The court held that, viewing the evidence and reasonable inferences in Norton’s favor, the jury could reasonably find the mower defectively designed based on the absence of a blade-stop/operator-presence safety device.
- The court concluded that the trial judge applied an overly demanding view of the proof and improperly substituted the court’s judgment for the jury’s on defect and causation.
- The case was remanded with instructions consistent with reinstating the jury’s verdict for Norton.

## Legal Principles

- A JNOV (like a directed verdict) is proper only when the evidence, and all reasonable inferences from it, so strongly favors the moving party that reasonable jurors could not reach a contrary verdict.
- In reviewing JNOV, the court must not weigh witness credibility or choose among competing reasonable inferences; it must view the record in the light most favorable to the nonmoving party.
- In a strict-liability design-defect case, the plaintiff must present evidence from which a reasonable jury can find that the product was in a defective condition and unreasonably dangerous when it left the manufacturer’s control.
- A design-defect claim may be supported by evidence that safer alternative designs or safety devices were available and could have reduced the risk of harm without defeating the product’s utility.
- Causation may be proved by circumstantial evidence; the plaintiff need not recreate the accident with complete precision if the record permits a reasonable inference that the alleged design defect was a legal cause of the injury.
- A jury may draw reasonable inference chains from the evidence; uncertainty about the exact mechanics of the injury does not require judgment for the defendant where the jury’s causation finding remains reasonable on the full record.

## Conclusion

The Eleventh Circuit held that the district court erred in taking the case away from the jury after a plaintiff’s verdict on strict products liability: the evidence allowed reasonable jurors to find that Snapper’s mower was unreasonably dangerous because it lacked an operator-presence/blade-stop safety device and that this design choice could be found to have caused Norton’s blade injury during the accident, so JNOV was improper and the jury’s verdict had to be reinstated.


Norton v. Snapper Power Equipment, 806 F.2d 1545 (1987)