Weisgram v Marley Case Brief - Daniella Daganasol

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School
Southwestern College, California **We aren't endorsed by this school
Course
LAW MISC
Subject
Law
Date
Sep 14, 2023
Pages
1
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Weisgram v. Marley Co., 528 U.S. 440 (2000) Facts: On December 30, 1993, a fire broke out in Bonnie Weisgram's house. Firefighters discovered Bonnie dead from carbon monoxide poisoning when they got on the scene. Chad Weisgram, Bonnie's son, filed a products liability lawsuit against Marley Co., the maker of the heated baseboards in Bonnie's home, claiming that a flaw in the electric baseboards was what started the fire that killed Bonnie. Three specialists who testified that the heater had a flaw that caused it to overheat and catch fire were given by Weisgram as evidence during the trial. Marley objected to this testimony, claiming that it violated F.R.E. 702 and the criteria outlined by the Supreme Court in Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993), and was therefore inadmissible. Marley appealed the jury's decision in favor of Weisgram. The court of appeals overturned the decision, stating that Weisgram had not given enough evidence to support the jury verdict without the testimony of its experts, which was inadmissible because it was speculative and not supported by science. The United States Supreme Court accepted Weisgram's appeal and granted certiorari. Issues: When it finds that evidence was improperly entered at trial and the remaining evidence does not support a viable case, can an appeal court order judgment as a matter of law? Holding: Yes. When it finds that evidence was improperly entered at trial and the remaining evidence does not support a viable case, an appeal court may direct judgment as a matter of law. A court may give a judgment as a matter of law when a party has been completely heard and there is not a legal basis for a jury to rule in favor of the party on that issue, according to Federal Rule of Civil Procedure 50. According to the Court's decision in Neely v. Martin K. Eby Construction Co., Inc., 386 U.S. 317 (1967), the appellate court has the authority to order the entry of judgment for the moving party if the trial court erroneously dismisses an application for a judgment as a matter of law. In that case, it was said that the appellate court had three choices if it determined that the trial court had improperly rejected a judgment as a matter of law. It may: (1) order a new trial; (2) remand the matter to the trial court, which will then determine whether a new trial or the entry of a judgment in favor of the defendant is more appropriate; or (3) order a judgment as a matter of law in favor of the defendant. In this situation, it is reasonable to order Marley to receive a judgment. Rationale: Weisgram's expert testimony was insufficient to support the jury's decision. Since Daubert, parties are reminded that in order for their expert testimony to be admitted into evidence, it must meet high reliability standards. The fact that the court of appeals used this criteria and determined that the testimony did not meet the proper threshold did not come as a surprise to Weisgram. The court of appeals further determined that this case was not a close call. It is not an abuse of discretion in this instance to not remand the case to the trial court for a new trial. The court of appeals' decision is upheld.
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