Superior Court rejects Honda’s call for new trial in $55M case

By David Hutton | May 11, 2017

PHILADELPHIA — The state Superior Court has rejected American Honda Motor Co.’s motion for a new trial after a lower court’s jury awarded $55.3 million in damages to Carlos Martinez, who was paralyzed in an accident in a Honda vehicle.

In rejecting the motion for the new trial on April 17, the Superior Court found no legal errors in the lower court’s trial or judicial rulings. It ruled that a Pennsylvania Supreme Court decision in Tincher v. Omega Flex Inc. overruling a dispositive product liability case didn’t impact the Honda case.

“We find that the trial court, even in light of Tincher, properly instructed the jury and precluded certain evidence,” the court wrote.

On May 1, 2010, Martinez was driving a 1999 Acura Integra when he lost control of the vehicle. His car left the roadway and rolled over twice. He sustained serious injuries from the accident that rendered him a quadriplegic. Acura is a division of Honda.

In their lawsuit against Honda, Martinez and his wife, Rosita de los Santos de Martinez, alleged the seatbelt in Martinez’s vehicle was defectively designed.

The case went to a jury trial June 17, 2014, and the jury returned a verdict against Honda, finding Honda negligent under two independent theories.

First, the jury found that the design of the seatbelt in Martinez’s car was defective and there was an alternative, safer and practicable design. The jury also determined the subject vehicle was defective because of Honda’s failure to warn.

The jury found both the defective design and Honda’s failure to warn were factual causes of Martinez’s injuries.

In its decision, the jury awarded $14,605,393.00 in future medical expenses, $720,321.00 in past and future lost earnings and earnings capacity, $25 million in past and future non-economic damages and $15 million in loss of consortium, totaling an award of $55,325,714.

On July 7, 2014, Honda filed a post-trial motion.

The trial court heard argument on the motion that addressed the issue of the impact of the Tincher case on the trial court’s evidentiary rulings and jury instructions.

On Jan. 21, 2015, the trial court denied Honda’s post-trial motion and entered judgment in favor of Martinez in accordance with the jury’s allocation of damages. 

Honda filed an appeal claiming the verdict was “excessive and illegal."

The automaker contended the trial court failed to instruct the jury that Martinez’s lawyers had the burden of proving that the product was “unreasonably dangerous.”

The appeal also questioned whether the trial court's design defect jury instruction and warning-defect claims were in error.

According to court records, Honda’s appeal also claimed the design-defect claim is preempted by federal motor vehicle regulations and Martinez’s lawyers offered no causation evidence that he would have heeded any additional warnings. The automaker also contended the only alternative design Martinez’s lawyers presented to the jury did not meet federal regulations.

Court documents also note that Honda contended the damages awarded were excessive and violated Pennsylvania law and due process.

In issuing the opinion, Judge Alice Beck Dubrow said the trial court did not abuse its discretion in concluding that the jury’s verdict in this case did not shock its sense of justice, nor in declining to find that partiality, prejudice, mistake, or corruption influenced the jury in its determination of the award.

“Our review of the record indicates that appellees presented ample evidence of Mr. Martinez’s injuries and how they impact him and his family now and for the rest of his life,” Dubrow wrote. “Moreover, the trial court’s opinion on this issue, albeit brief, reflects that it properly weighed the factors set forth in (a previous case). Accordingly, no relief is due on this claim.”

Honda can still appeal the decision to the state Supreme Court.

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Organizations in this Story

American Honda Motor Co. Pennsylvania Supreme Court Superior Court of Pennsylvania

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