Hazel Lee, Individually and as of the Estate of Robert Alex Lee v. Cnh America, LLC

CourtCourt of Appeals of Georgia
DecidedJuly 9, 2013
DocketA13A0696
StatusPublished

This text of Hazel Lee, Individually and as of the Estate of Robert Alex Lee v. Cnh America, LLC (Hazel Lee, Individually and as of the Estate of Robert Alex Lee v. Cnh America, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hazel Lee, Individually and as of the Estate of Robert Alex Lee v. Cnh America, LLC, (Ga. Ct. App. 2013).

Opinion

FOURTH DIVISION DOYLE, P. J., MCFADDEN and BOGGS, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

July 9, 2013

In the Court of Appeals of Georgia A13A0696. HAZEL LEE, INDIVIDUALLY AND AS EXECUTOR OF THE ESTATE OF ROBERT ALEX LEE v. CNH AMERICA, LLC. et al.

BOGGS, Judge.

In this product liability action, Hazel Lee, the wife and executrix of Robert Lee,

appeals from a defense verdict in favor of CNH, America, LLC, and CNH Italia

(collectively “CNH”).1 Mrs. Lee contends on appeal that the trial court erred in

charging the jury on assumption of the risk, misuse of a product, and spoliation. She

also asserts that the trial court erred by allowing a 30 (b) (6) defense witness to give

expert opinion testimony. Based upon the “any evidence” standard of review on

appeal, the trial court did not err in its charges, and Mrs. Lee cannot demonstrate

1 CNH Italia manufactured the tractor at issue, and CNH America marketed, distributed, and sold the tractor. prejudice resulting from the alleged opinion testimony offered by the defense witness.

We therefore affirm.

The record shows that a new tractor manufactured by the defendants was

delivered to Robert Lee on April 30, 2007. Three days later, on May 3, 2007, his wife

found his body trapped between the elevated cultivator and the rear tractor wheel with

the engine running. The evening before Mr. Lee’s death, he called his brother-in-law

and told him that he loved his new tractor, that “the lift was all the way up or all the

way down,” and asked him to “come that Saturday to try to help him figure out what

it was.” Evidence presented at trial showed that Lee had owned three or four tractors

for over 35 years before purchasing the CNH tractor, was mechanically inclined, and

“could fix anything.”

The tractor included a “lift-o-matic” feature (also called “the fast raise/fast

lower system”) that allowed the operator to flip a single switch to quickly raise or

lower any attached implement. This switch was located on the right side of the

operator’s seat. The tractor also included a height limit adjustment knob that was used

to adjust the preset height at which an attached implement would raise when the lift-

o-matic switch was in the “fast raise” position. This knob was located on the rear of

the tractor behind the operator’s seat. In order to adjust the preset height, the operator

2 would have to get out of the operator seat and go behind the tractor “in between the

tractor and the implement.” If the height limit adjustment knob is loosened while the

tractor is running and the lift-o-matic switch is in the fast raise position, the

implement will instantly raise to its full height.

It is undisputed that Lee read the operator’s manual for the tractor “every

night” and that he received a copy before the tractor was delivered. The operator’s

manual contained numerous warnings about turning the tractor engine off before

servicing or adjusting the tractor or its implements. Additionally, the portion of the

manual addressing the height limit adjustment feature instructed the operator to place

the lift-o-matic feature in the fast lower position and to “switch off the engine” before

loosening the knob. If the lift-o-matic feature had been placed in fast lower or the

engine had been turned off, Lee would not have been crushed during any attempt to

adjust the knob while standing between the implement and the tractor. Finally, a

sticker on the right rear fender of the tractor stated: “Lift raises or drops completely

when fast raise/lower lift control is operated. Do not stand on the implement or in

between implement and tractor while operating fast raise/lower lift control or injury

may result.” The jury heard evidence that, two months after Lee’s death, CNH

3 changed the warning on its tractor and in its manual “related to the height limit

adjustment feature and being back there with the engine running.”

The salesperson that sold the tractor to Lee testified that when he delivered the

tractor, Lee asked him to explain the fast raise and lower system. The salesperson

explained the proper procedure and demonstrated it “half a dozen or more times”

before asking Lee to “do it two or three times.” When “demonstrating the proper

procedure to adjust the height limit function,” the salesperson “instruct[ed] him to

turn the engine off before loosening the knob.” The salesperson did not tell Lee he

would be exposing himself to danger or risk if he failed to turn the engine off because

Lee had “been around tractors and equipment all his life” and it would have been

insulting to tell him something he already knew. According to the salesperson, the

risk of going between the tractor and the implement when the engine was running was

“open and obvious” and one which he believed that Lee understood. After spending

almost two hours with Lee, the salesperson believed that Lee knew how to use the

lift-o-matic and height limit control features properly and that Lee understood that the

engine should be off when the height limit was adjusted. Each time the salesperson

or Lee practiced adjusting the height control in the back of the tractor, they turned the

engine off before doing so.

4 While CNH’s counsel asked Lee’s counsel to inspect the tractor on July 5,

2007, less than two months after the accident and before any lawsuit had been filed,

their request was refused, and they were not allowed to do so until August 2009, over

two years after Lee’s death and four months after Mrs. Lee filed her complaint. In the

intervening period, the tractor was inspected by two consultants on behalf of Mrs.

Lee, and her son operated the tractor during the inspection, doing “what they told me

to do.” During his testimony at trial, the son denied that he or the consultants turned

any knobs behind the tractor. On February 2, 2009, the tractor was transferred to

Benedict Engineering in Florida and stored in unknown conditions. On July 13, 2009,

the tractor was moved to Weil Wrecker in Birmingham, Alabama and stored in an

enclosed building that may not have had climate control.

During his inspection of the tractor in August 2009, a product performance

specialist with CNH,2 John Bucher, obtained permission from plaintiff’s

representative before loosening the height adjustment knob. Bucher testified at trial

2 Bucher’s background and training included: diplomas from high school and a technical school for welding and blueprint reading, work as a service technician and manager for a John Deere dealership, completion of a four-year prototype specialist training program with Ford New Holland, eight years work building and testing prototype tractors and hay tools, seven years work in product technical support, and four years work as a performance specialist. CNH sells New Holland tractors.

5 that “[t]he first time I went to loosen the knob I made the comment, wow, it’s tight

and I couldn’t loosen it, . . . it was extremely tight.” He assumed that the cam may

have been paint stuck which “would eliminate the possibility that Mr. Lee loosened

the knob and the lift came up.” When he later learned from the dealer that the cam

was loosened before delivery, he eliminated the paint stuck theory.

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