No Abuse Of Discretion In Denying Addition Of New Liability Theory
ALDRIDGE v. FOREST RIVER, INC. (March 8, 2011)
Linda Aldridge and her husband purchased a recreational vehicle manufactured by Forest River. The RV was equipped with a step controller, a device that expands and retracts the vehicle's steps. The step controller was manufactured by Specific Cruise Systems. During a Florida vacation, Linda Aldridge fell while descending the steps. Aldridge brought suit against Forest River and SCS, alleging theories of strict liability in that the step controller retracted without warning, causing her fall. Throughout motion practice, expert discovery, and interrogatory answers, Aldridge limited her theory of liability to the allegedly defective step controller. Shortly before trial, over Aldridge’s objection, the trial court granted Forest River's motion in limine to bar any argument that the RV itself was the defective product. At trial, Aldridge attempted to amend her complaint to allege that the RV was a defective product. The court denied her request. The trial court also amended Aldridge's jury instruction that would have asked the jury to determine if the RV was defective. The jury found in favor of the two defendants. Judge Bucklo (N.D. Ill.) denied the request for a new trial, concluding that Aldridge had maintained throughout the proceedings that the step controller was the cause of her injuries and expanding the theory of liability would prejudice the defendants. Aldridge appeals.
In their opinion, Circuit Judges Kanne and Tinder and District judge Herndon affirmed. The Court noted that it reviewed all of Aldridge’s contentions -that the district court erred in granting the motion in limine, denying the motion to amend, amending the jury instruction, and denying the motion for a new trial --- under an abuse of discretion standard. Not surprisingly, the Court was not persuaded by any of Aldridge's contentions. The grant of the motion in limine conformed to the expectations of the parties and prevented surprise. The denial of the motion to amend prevented the reopening of discovery and the addition of the new liability theory during trial. The amendment of the jury instruction conformed to the evidence presented during the trial and was not misleading or improper. The denial of the motion for new trial was proper when there was a reasonable basis to support the verdict.
