Elaine Petroleum Distributor, Inc., and Qingdao Xiyingmen Double Camel Tyre Co., Ltd. v. Betsy Snyder, Administratrix of the Estate of Michael Snyder

2022 Ark. App. 59, 640 S.W.3d 704
CourtCourt of Appeals of Arkansas
DecidedFebruary 9, 2022
StatusPublished
Cited by3 cases

This text of 2022 Ark. App. 59 (Elaine Petroleum Distributor, Inc., and Qingdao Xiyingmen Double Camel Tyre Co., Ltd. v. Betsy Snyder, Administratrix of the Estate of Michael Snyder) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elaine Petroleum Distributor, Inc., and Qingdao Xiyingmen Double Camel Tyre Co., Ltd. v. Betsy Snyder, Administratrix of the Estate of Michael Snyder, 2022 Ark. App. 59, 640 S.W.3d 704 (Ark. Ct. App. 2022).

Opinion

Elizabeth Perry I attest to the accuracy and integrity of this document Cite as 2022 Ark. App. 59 2023.08.22 11:21:09 ARKANSAS COURT OF APPEALS -05'00' DIVISION I 2023.003.2026 No. CV-19-686 9 ELAINE PETROLEUM DISTRIBUTOR, Opinion Delivered February 9, 2022 INC., AND QINGDAO XIYINGMEN DOUBLE CAMEL TYRE CO., LTD. APPELLANTS/CROSS-APPELLEES APPEAL FROM THE PHILLIPS COUNTY CIRCUIT COURT V. [NO. 54CV-13-204]

BETSY SNYDER, ADMINISTRATRIX HONORABLE RICHARD L. OF THE ESTATE OF MICHAEL PROCTOR, JUDGE SNYDER, DECEASED APPELLEE/CROSS-APPELLANT AFFIRMED ON DIRECT APPEAL; CROSS-APPEAL DISMISSED

BART F. VIRDEN, Judge

In this products-liability case, appellee Michael Snyder 1 was injured when a tire

manufactured by appellant Qingdao Xiyingmen Double Camel Tyre Co., Ltd., and sold by

Elaine Petroleum Distributors, Inc., exploded while he was mounting it. 2 A jury returned a

verdict for Snyder on all of his claims, assessing his damages at $2.5 million and finding

Qingdao 75 percent at fault and Elaine Petroleum 25 percent at fault. On appeal, Qingdao

1 Michael Snyder died after the trial while this appeal was being perfected. Sandra Snyder, his wife, was substituted as plaintiff in this case. Sandra Snyder has now passed away. Betsy Snyder was appointed administratrix of the estate of Michael Snyder by the Phillips County Circuit Court and substituted as the appellee in this case. 2 Elaine Petroleum was originally an appellant in this case. However, Snyder and Elaine Petroleum reached a settlement while this appeal was pending and Elaine Petroleum was dismissed from the appeal and cross-appeal by order of this court entered on September 16, 2020. argues that it lacks sufficient minimum contacts with Arkansas, that the circuit court should

have directed a verdict in its favor on Snyder’s negligence and warranty claims, that the

court should not have allowed evidence of subsequent warranty claims occurring after the

incident in question over a subsequent-remedial-measures objection, and that the court

should have granted a new trial or ordered remittitur because the damages award was

excessive and not supported by substantial evidence. Snyder cross-appeals from the form of

the judgment or, alternatively, argues that Elaine Petroleum’s proportionate share of fault

should be increased. We affirm on direct appeal and dismiss the cross-appeal.

I. Factual Background & Procedural History

On July 25, 2011, Michael Snyder was working in his family-owned mechanic’s

shop airing up a trailer tire that he was mounting on a wheel for a customer when the tire

exploded, hitting Snyder and causing serious injury to him. Qingdao, a Chinese company,

manufactured the tire, and it was sold to Snyder’s customer by Elaine Petroleum.

Snyder filed his complaint against both Qingdao and Elaine Petroleum on September

4, 2013. 3 Snyder’s complaint as amended asserted claims for negligence, breach of express

and implied warranties, and strict liability against the defendants. Qingdao filed a document

captioned “Motion to Dismiss and Answer to First Amended Complaint” on June 20, 2014.

Qingdao contended that the circuit court lacked personal jurisdiction because it was not

properly and timely served with process. On July 24, 2014, Qingdao filed a brief in support

of its motion to dismiss. In addition to the service issues, Qingdao raised for the first time

3 Snyder also sued the maker of the tire-mounting machine he had been using at the time of the accident. The claims against the tire-mounting machine manufacturer were eventually dismissed.

2 the issue of whether it had sufficient minimum contacts with Arkansas and whether Snyder

had properly pled facts showing such contacts.

The hearing on Qingdao’s motion to dismiss focused on whether Qingdao had

sufficient minimum contacts with Arkansas. Snyder argued that Qingdao had waived the

issue because it had not raised the issue in its answer and motion. At the conclusion of the

hearing, the court denied the motion from the bench, finding that Qingdao’s placing the

tire in the stream of commerce to be used by customers in the United States was sufficient

contact with the State of Arkansas to give the Arkansas courts jurisdiction over it. The court

reasoned that to rule otherwise would effectively make the manufacturer immune from suit.

In its written order, the circuit court found that Qingdao had sufficient contacts with the

State of Arkansas to give the court jurisdiction over the parties and the subject matter of the

lawsuit.

The case proceeded to trial before a jury in October 2018. The circuit court

instructed the jury on strict liability, negligence, implied warranty, and express warranty.

The jury answered special interrogatories at the close of the case making separate findings

of liability on each of Snyder’s claims. In interrogatory 1, the jury found that the tire

manufactured, sold, assembled, or otherwise distributed by the defendants was in a defective

condition that rendered it unreasonably dangerous and that it caused damages to Snyder. In

interrogatories 2 and 3, the jury found that each defendant was negligent. Each defendant

was also found to have breached implied warranties of fitness for ordinary purposes and

express warranties. Damages were assessed at $2.5 million with fault allocated 75 percent to

Qingdao and 25 percent to Elaine Petroleum. The jury’s allocation of fault resulted in

3 judgment against Qingdao in the sum of $1,875,924.75 and against Elaine Petroleum in the

sum of $625,066.25. 4

Prior to the entry of the judgment, issues arose over the form of the judgment. The

parties briefed the issue for the circuit court. The defendants contended the form of the

judgment should reflect separate proportional liability as per the jury’s allocation of fault.

Snyder contended that judgment should be joint and several because the strict-products-

liability verdict was not dependent on “fault” as between the defendants. The circuit court

agreed with the defendants and entered the defendant’s proposed judgment in accordance

with the jury’s findings on December 3, 2018.

Snyder then moved postjudgment, in the alternative, to have the proportional share

of the judgment against Elaine Petroleum increased under Ark. Code Ann. § 16-55-203

(Repl. 2005), arguing that the proportional share of the judgment against Qingdao was not

reasonably collectable. Snyder supported the motion with an affidavit from an expert in

Chinese legal matters and collection efforts explaining that legal barriers erected by China

and the refusal of Qingdao to pay judgments in the past made this judgment “reasonably

uncollectable.”

Each defendant filed separate posttrial motions for a judgment NOV and remittitur.

In its motion, Qingdao asserted that the court lacked jurisdiction over it because of a lack

of proper service of process; that the damages were excessive, appearing to have been given

under the influence of passion or prejudice; that the court had erred in the admission of

4 The amount of each judgment included a proportionate share of Snyder’s filing fee plus the costs of service on that defendant.

4 certain evidence; and that the court had erred in denying its motions for directed verdict.

Qingdao adopted and incorporated the motion and brief of Elaine Petroleum.

The circuit court denied Snyder’s motion to increase Elaine Petroleum’s liability.

Qingdao’s motion for JNOV was deemed denied.

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