Bobo v. Mitsubishi Motors Corp.

10 Mass. L. Rptr. 108
CourtMassachusetts Superior Court
DecidedMarch 8, 1999
DocketNo. 9500300
StatusPublished
Cited by1 cases

This text of 10 Mass. L. Rptr. 108 (Bobo v. Mitsubishi Motors Corp.) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bobo v. Mitsubishi Motors Corp., 10 Mass. L. Rptr. 108 (Mass. Ct. App. 1999).

Opinion

Connon, J.

This matter is before the Court on plaintiffs motion pursuant to Mass.R.Civ.P. 37, 59 and 60(b) to set aside the jury verdict and grant a new trial and to impose sanctions on the grounds that such extraordinary relief is warranted by the defendant’s misconduct. For the reasons discussed below the plaintiffs motion is ALLOWED.

Also before the Court is the plaintiffs claim of unfair and deceptive trade practices in violation of G.L.c. 93A. The Court takes no action with regard to this claim because a new trial is allowed herein.

[109]*109Background

On July 18, 1990, Karen Bobo purchased a new Mitsubishi Gallant that was designed, manufactured and tested by Mitsubishi Motors Corporation and distributed by Mitsubishi Motor Sales of America. On the morning of January 29, 1993, Karen Bobo was operating the Gallant at a speed of approximately 40 mph or less. Another vehicle failed to obey a stop sign and struck Ms. Bobo’s car on the passenger side. The front passenger side door opened upon impact. The car spun clockwise and slid into a tree that intruded into the car via the open passenger side door and struck Ms. Bobo’s head. She suffered catastrophic brain injuries and remains in a persistent vegetative state.

Plaintiff James Bobo, the spouse of Karen Bobo brought suit against the defendants on September 19, 1994, contending that the defendants breached their warranties and were negligent, and that their conduct amounted to a violation of G.L.c. 93A. Specifically, plaintiffs allege that the Mitsubishi Gallant, owned and operated by Karen Bobo, was designed and built with a defective door latching system which allowed for unintentional door openings during foreseeable collisions resulting in inadequate protection to occupants, and that defendants failed to warn of the unreasonably dangerous condition.

On May 12, 1998, this Court issued an order granting plaintiffs motion to compel responses to plaintiffs second request for production of documents.3 The Court’s order was not limited. Defendants produced only a one-line computer summary entry for over 51,000 warranty incidents involving door latch defects and failures. Defendants did not produce the full claim information from dealers and customers prior to trial in violation of the Court’s order.

The trial commenced on October 6, 1998 During the trial the defendants, despite repeated promises to the contrary, continued to refuse to comply with the Court’s directives.4 In response to a motion by the plaintiff for sanctions, defendant produced an affidavit of Michael Impullitti, the Warranty Administration Manager. Mr. Impullitti attested to the fact that when a hard copy of warranty data stored in the electronic warranty system is needed, such document is created in the form of a printout with a number of line entries, setting forth data fields.5 The defendant’s response to the request for such hard copies was woefully deficient. The defendant merely produced a general computer summary, consisting of one-line entries for approximately 51,000 claims. The defendant never produced the full warranty information, which, as their Warranty Administration Manager attests, they were capable of producing.

Further, the defendant made misrepresentations to the Court regarding the Mitsubishi latching system.6 Contrary to counsel’s suggestion at trial, Mitsubishi employs the same type of latching system in all models. The misrepresentation induced the Court to limit the plaintiff presentation to evidence of identical latches.7

The plaintiff suffered substantial prejudice from the defendant’s conduct in concealing information that would have increased both the quality and quantity of liability evidence regarding what exactly the defendant knew about performance failures of similar doors and latching systems.

On November 2, 1998, the jury returned a verdict in favor of the defendants on the negligence and warranty claims.8

Discussion

The plaintiff petitions this Court for relief from judgment, allowance of a new trial and the imposition of sanctions on the grounds that the defendant has additional evidence on the question of liability that was not presented at the trial in violation of an express order to do so. Rule 60(b)(3) of the Massachusetts Rules of Civil Procedure provides that"... the court may relieve a party or his legal representative from a final judgment, order, or proceeding for . . . fraud . . . misrepresentation, or other misconduct of an adverse parly.9 The Rule permitting relief from judgment is remedial in nature and subject to liberal interpretation and application in a situation where mischief leading to judgment occurs in the pretrial stage. Berube v. McKesson Wine & Spirits Co., 7 Mass.App.Ct. 426, 429 (1979). A motion for relief from judgment is addressed to the sound discretion of the trial judge. Chiu-Kun Woo v. Moy, 17 Mass.App.Ct. 949 (1983), rev. denied 391 Mass. 1104. Exercise of discretion with respect to a motion for relief from judgment involves the absence of arbitrary determination, capricious disposition or whimsical thought. Berube, 7 Mass.App.Ct. at 429, quoting Davis v. Boston Elev. Ry., 235 Mass. 482, 496 (1920). In considering a motion for relief from judgment, the judge should consider whether the conduct involved rises to the level of a ”deliberate and calculated plan to use the judicial system in an unconscionable and fraudulent manner." Pina v. McGill Development Corp, 388 Mass. 159, 168 (1983).

Massachusetts Rules of Civil Procedure Rule 59(a)(1) “permits the granting of a new trial ‘in an action in which there has been a trial by jury, for any of the reasons for which new trials have heretofore been granted in actions at law in the Commonwealth.’ ” Galvin v. Welsh Mfg. Co., 382 Mass. 340, 342 (1981). Allowance of a new trial is within the trial court’s discretion. Commonwealth v. Johnson Insulation, 425 Mass. 650, 668 (1997). A new trial “ought not to be granted unless on a survey of the case as a whole it appears to the judicial conscience and judgment that otherwise a miscarriage of justice will result.” John J. Williams Ins. Agency v. Putignano, 36 Mass.App.Dec. 135, 140 (1967). A judge may grant a new trial for any cause which in his judgment may have prevented a party from having had a fair trial. [110]*110Bondsville Realty Corp. v. Diamond Internatl. Corp., 44 Mass.App.Dec. 164, 168 (1970), affirmed 360 Mass. 870. In ruling on a motion for a new trial a judge must necessarily consider the probative force of the evidence and not merely the presence or absence of any evidence upon a disputed point. Phachansiri v. City of Lowell, 35 Mass.App.Ct. 576, 579-80 (1983), rev. denied 416 Mass. 1110.

Massachusetts Rules of Civil Procedure Rule 37(b), as amended, 390 Mass. 1208 (1984), concerns sanctions for failure to comply with an order of a court. Since January 1, 1984, sanctions under Rule 37(b) need not be based on a wilful failure to comply. The purpose of the amendment was “to increase compliance with discovery orders, by making it easier for parties to achieve, and judges to award, sanctions for failure to comply with a discovery order.” Greenleaf v. Massachusetts Bay Transportation Authority, 22 Mass.App.Ct. 426, 430-31 (1986) quoting Reporters’ Notes to Mass.R.Civ.P. 37, Mass. Ann.

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10 Mass. L. Rptr. 108, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bobo-v-mitsubishi-motors-corp-masssuperct-1999.