Bradley v. Fontaine Trailer Co. Inc.
A court can exclude evidence that a sports utility driver who had a zero percent blood-alcohol level at the time of a motor-vehicle accident had drunk a beer earlier in the day. At about 4:50 a.m. on Jan. 17, 2003, a Freightliner tractor driver who was hauling a flat-bed semi-trailer allegedly collided with the concrete median barrier that separated the north and southbound travel lanes on Interstate 95. The tractor separated from the trailer, which straddled the median barrier and partially obstructed the northbound travel lane. A sports utility vehicle with eight passengers collided with the trailer. The estates of the decedents and individuals who were injured brought a product-liability action against Fontaine Trailer Co., alleging that the trailer was defectively designed. The defendant moved to exclude evidence of Federal Motor Carrier Safety Administration regulations and argued that they do not apply to manufacturers. The court found the regulations, which concern trailer safety, could be relevant to a decision about whether the trailer was unreasonably dangerous at the time of sale. The court denied the defendant's motion. A jury can be informed that manufacturers are not required to comply and that compliance is not dispositive of the issue of whether there was a product defect. Although the driver of the sports utility vehicle had a zero percent blood-alcohol content, there was evidence that he had had a beer earlier that day. The plaintiffs moved to preclude evidence of beer consumption. The defendants argued that beer consumption could have increased fatigue. Countless factors could have influenced the driver's fatigue. The possibility of unfair prejudice was greater than the probative value. "The inferences defendant wishes the jury to draw," wrote the court, "are too weak to overcome the powerful, unfair prejudice attached to fraternity binge-drinking." The court granted the plaintiffs' motion to exclude evidence of alcohol consumption. The court also granted the motion to sever Marc Grenier's claims from those of the other plaintiffs. Grenier allegedly made admissions concerning the fatigue of the sports utility driver constituting a substantial cause of the motor-vehicle accident. Grenier's admissions could significantly prejudice the other plaintiffs.