## Facts

- Step-Saver Data Systems, Inc. was a value-added reseller that assembled and sold multi-user computer systems combining IBM computers, Wyse-60 terminals, and multi-user operating system software from another vendor.
- Wyse Technology manufactured the Wyse-60 terminals used in Step-Saver’s systems.
- Step-Saver’s customers experienced system problems and sued Step-Saver; Step-Saver sought to shift liability to Wyse through warranty-based claims.
- Step-Saver alleged Wyse’s terminals were defective and that Wyse breached (1) an express warranty to repair or replace defective terminals and (2) an implied warranty of fitness for Step-Saver’s particular multi-user purpose.
- Before trial, the court granted summary judgment for Wyse on Step-Saver’s misrepresentation and negligence-based claims, leaving warranty and contract-related theories for trial.
- After a bifurcated, ten-day jury trial, the jury found for Wyse on Step-Saver’s express-warranty and implied-warranty claims, answering “no” on breach and proximate causation.
- Step-Saver moved for a new trial against Wyse, challenging the sufficiency of the evidence and alleging prejudicial legal and procedural errors.

## Issues

1. Whether the jury’s verdict rejecting breach of express warranty and implied warranty of fitness was against the great weight of the evidence.
2. Whether prior summary-judgment rulings, evidentiary rulings, jury instructions, or interrogatories contained prejudicial error requiring a new trial.
3. What standard governs a district court’s decision to disturb a civil jury verdict through a new trial order.

## Decision

- The court denied Step-Saver’s motion for a new trial.
- The court held the jury’s “no breach” and “no causation” findings on express warranty were supported by sufficient evidence.
- The court held the jury’s “no breach” and “no causation” findings on implied warranty of fitness were supported by sufficient evidence, including permissible findings on knowledge, reliance, breach, and causation.
- The court found no prejudicial error in the earlier summary-judgment dispositions, evidentiary rulings, jury instructions, or interrogatories that would justify setting aside the verdict.

## Legal Principles

- A new trial may be granted only when the verdict is against the clear weight of the evidence, produces a miscarriage of justice, or reflects a seriously erroneous result.
- A district court should not replace the jury’s role on disputed facts and credibility determinations unless the evidence so strongly favors one side that the verdict cannot stand.
- Express-warranty liability requires proof of breach and proximate causation of the claimed damages; a jury may reject the claim if the defendant’s repair/replacement performance or causation proof is disputed.
- Implied warranty of fitness for a particular purpose requires proof that the seller had reason to know the buyer’s particular purpose and that the buyer relied on the seller’s skill or judgment, plus breach and proximate causation.
- Evidentiary rulings are reviewed for abuse of discretion and must be shown to have caused prejudice sufficient to undermine confidence in the verdict.
- Jury instructions and interrogatories warrant a new trial only if they misstate controlling law or likely mislead the jury in a way that affects the verdict.

## Conclusion

The court left the jury’s defense verdict intact, holding that Step-Saver failed to show the warranty findings were contrary to the clear weight of the evidence or that any pretrial or trial rulings created prejudice warranting a new trial.


Step-Saver Data Sys., Inc. v. Wyse Tech., 752 F. Supp. 181 (E.D. Pa. 1990)