## Facts

- William Rozier, a passenger in a 1969 Ford Galaxie 500, died from burns after a rear-end collision ruptured the car’s fuel tank and caused a fire on a Georgia highway.
- His widow sued Ford in federal court under diversity jurisdiction, alleging negligent fuel-tank design caused his death.
- During discovery, plaintiff sought information on Ford’s knowledge of fuel-tank design alternatives and cost/feasibility considerations.
- Ford’s discovery responses omitted a 1971 internal “Confidential Cost Engineering Report” (the Mancini report) comparing costs of alternative fuel-tank redesigns for full-size Ford vehicles.
- Ford’s counsel located the Mancini report before trial but did not produce it and did not correct an interrogatory answer that became materially incomplete once the report was found.
- After a week-long trial, the jury returned a defense verdict for Ford and judgment was entered.
- About ten months later, plaintiff learned of the Mancini report and moved for a new trial under Rule 60(b)(2) and Rule 60(b)(3) while an appeal from the judgment was pending.
- The district court denied Rule 60(b) relief without detailed reasons; the appeal from that denial was consolidated with the appeal from the judgment.
- At trial, the district court admitted evidence that the driver who struck the Ford pleaded guilty to manslaughter arising from the collision.

## Issues

1. Whether denial of a new trial was an abuse of discretion under Fed. R. Civ. P. 60(b)(3) where Ford failed to produce a relevant document within the scope of discovery and failed to correct an interrogatory response that became materially inaccurate.
2. Whether plaintiff independently satisfied Rule 60(b)(2) requirements for relief based on newly discovered evidence.
3. Whether admitting evidence of the striking driver’s manslaughter guilty plea was an abuse of discretion in a design-defect/negligent-design trial, and whether it contributed to reversible error.
4. Whether Ford’s conduct constituted “fraud on the court” or instead fell within ordinary Rule 60(b)(3) misconduct subject to Rule 60 timing limits.

## Decision

- The Fifth Circuit reversed the judgment for Ford and reversed the order denying Rule 60(b) relief.
- The court held Ford’s nondisclosure of the Mancini report, and failure to supplement a materially incomplete interrogatory answer, constituted “misconduct” under Rule 60(b)(3).
- The court found the misconduct prejudiced plaintiff by denying information that could have materially altered how she tried the case, including impeachment and proof on feasibility/cost of safer alternatives.
- The court held the district court abused its discretion by admitting evidence of the striking driver’s manslaughter guilty plea because of substantial unfair prejudice and limited probative value on Ford’s design liability.
- The case was remanded for a new trial.

## Legal Principles

- Relief under Fed. R. Civ. P. 60(b)(3) requires a showing that the adverse party’s fraud, misrepresentation, or misconduct substantially interfered with the movant’s ability to fully and fairly present her case; the movant need not prove the verdict would have been different.
- A party has a duty under Fed. R. Civ. P. 26(e) to supplement or correct discovery responses when it learns a prior response is materially incomplete or incorrect and the additional information has not otherwise been disclosed.
- “Fraud on the court” is limited to extreme misconduct (e.g., bribery of a judge or jurors, or fabrication of evidence involving counsel) and is not established by ordinary discovery nondisclosure.
- In a civil products/design case, evidence of a third party’s criminal guilty plea may be excluded when its unfair prejudice and risk of jury confusion substantially outweigh any probative value.

## Conclusion

The Fifth Circuit ordered a new trial because Ford’s suppression of a key internal cost report and failure to correct discovery responses denied the plaintiff a fair opportunity to present her design-defect case, and the admission of the striking driver’s manslaughter plea further skewed the jury’s focus away from Ford’s alleged design negligence.


Rozier v. Ford Motor Co., 573 F.2d 1332 (5th Cir. 1978)