U.S. Eighth Circuit - The FindLaw 8th Circuit Court of Appeals Opinion Summaries Blog

Court Denies Toyota Appeal in Unintended Acceleration Case

In June 2017, the Eighth Circuit Court of Appeals upheld the $11 million judgment against Toyota stemming from an unintended acceleration case that left three people dead, and put the driver behind bars for over two years. Toyota requested reconsideration of the matter, and a month later, in August 2017, the Eighth Circuit upheld the judgment against them once again.

The big issue that Toyota sought reconsideration on, apart from the size of the judgment, involved the evidence of "other similar incidents." In the case, testimony from three other individuals, unrelated to the accident in the present case, described situations where their Toyota Camrys (of the same model year) suffered the unintended acceleration problem alleged to have caused the accident in the present case.

Reconsidering Reconsideration

The Eighth Circuit again explained to Toyota that the admission of "similar-incident" evidence is an issue within the discretion of a district court, and absent clear and prejudicial abuse of that discretion, it will not be overturned. The appellate court also found that the district court did not just admit any and all other similar incidents, but in fact carefully considered each beforehand, and limited the information. These facts serve to show that the court was careful to not abuse its discretion.

Furthermore, the appellate court noted that Toyota had the opportunity to cross examine the witnesses presenting the similar incidents and was able to differentiate the similar incidents from the case at bar, which serves to eliminate much of any alleged prejudice.

Toyota Saves an Interest Payment, Again

While the Eighth Circuit did agree that Toyota should not have been subjected to a judgment including prejudgment interest, the prior June 2017 decision reached the same conclusion as the August 2017 decision. 

The court reasoned that when various portions of a judgment are not easily distinguishable from one another (i.e. lost past wages and lost future earnings are lumped together as one award), then prejudgment interest cannot be awarded. This is due to the fact that under Minnesota law, which governed this matter, prejudgment interest is not available for all types of financial awards, such as lost future income, and can only be awarded where a judgment, or portion thereof, is clearly traceable to sources that permit an award of interest.

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