## Facts

- Anne K. Wilson owned a Vermont Castings wood-burning stove.
- On November 16, 1991, Wilson left a side door on the stove open to help start a fire.
- While standing near the open side door to warm herself, Wilson’s dress caught fire, causing severe burns, including loss of fingers on her left hand.
- Wilson and her husband, Oliver J. Larmi, sued Vermont Castings and related entities in federal court, pursuing a strict products liability theory based on defect and warnings.
- Wilson had never read or seen the stove’s owner’s manual, and the district court excluded the manual from evidence.
- After a multi-day jury trial, the jury found the stove was defective but found the defect was not a substantial factor in causing Wilson’s injuries, resulting in a verdict for defendants.
- After trial, Wilson’s counsel learned from a juror that another juror who owned a Vermont Castings stove discussed her own use of the stove during deliberations, including that she often left the side door open to start a fire.
- The juror also stated that she would not change her own behavior even if the stove carried a warning to keep the door shut; Wilson also alleged the juror consulted her own manual and shared its warning content.
- Wilson moved for a new trial, arguing (1) the jury was exposed to outside information during deliberations and (2) defendants improperly argued Wilson’s negligence in a strict liability case.
- The district court denied the motion, and Wilson appealed to the United States Court of Appeals for the Third Circuit.

## Issues

1. Whether the district court abused its discretion by denying a new trial based on alleged juror exposure to outside information, including a juror’s discussion of her personal stove use and alleged consultation of a stove manual not admitted into evidence.
2. Whether the district court abused its discretion by denying a new trial based on claims that defendants’ closing arguments improperly focused on Wilson’s negligent conduct in a strict products liability trial.

## Decision

- The Third Circuit affirmed the judgment and the order denying a new trial.
- The court held that the juror’s comments about her own experience using a similar stove were part of ordinary juror deliberation and did not justify setting aside the verdict.
- To the extent Wilson claimed the juror consulted a manual and relayed its contents, Wilson did not show prejudice sufficient to require a new trial in light of the record and the jury’s causation finding.
- The court rejected the claim that defendants’ arguments required a new trial, concluding that discussion of Wilson’s conduct was tied to causation and did not warrant reversal.

## Legal Principles

- Federal Rule of Evidence 606(b) generally bars using juror testimony to attack a verdict based on what occurred during deliberations, while allowing limited inquiry into whether “extraneous prejudicial information” or an “outside influence” reached the jury.
- Jurors may draw on their life experiences in evaluating evidence; discussion grounded in personal experience is ordinarily not treated as “extraneous” information.
- Even when material from outside the trial record is alleged to have reached deliberations, a new trial is not automatic; the moving party must show a meaningful likelihood of prejudice.
- Motions for a new trial are reviewed deferentially; appellate review focuses on whether the district court abused its discretion in denying relief.
- In a strict products liability case, evidence and argument about how the accident occurred may be relevant to causation (including whether an alleged defect was a substantial factor in producing the injury), even though ordinary negligence is not the theory of liability.

## Conclusion

In *Wilson v. Vermont Castings, Inc.*, the Third Circuit affirmed a defense verdict and the denial of a new trial after a jury found a wood stove defective but not a substantial factor in causing the plaintiff’s burn injuries. The court concluded that a juror’s comments based on her own use of a similar stove, and the claimed reference to a manual not admitted at trial, did not justify disturbing the verdict absent a sufficient showing of prejudice. The court also held that defendants’ trial arguments about the plaintiff’s conduct were permissible as they related to causation and did not require a retrial.


Wilson v. Vermont Castings, Inc., 170 F.3d 391 (1999)