Sheets v. Agro-West, Inc.

664 P.2d 787, 104 Idaho 880, 1983 Ida. App. LEXIS 228
CourtIdaho Court of Appeals
DecidedJune 7, 1983
Docket14382
StatusPublished
Cited by56 cases

This text of 664 P.2d 787 (Sheets v. Agro-West, Inc.) is published on Counsel Stack Legal Research, covering Idaho Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sheets v. Agro-West, Inc., 664 P.2d 787, 104 Idaho 880, 1983 Ida. App. LEXIS 228 (Idaho Ct. App. 1983).

Opinions

WALTERS, Chief Judge.

Defendants Agro-West, Inc. and its employee Layton Noe (hereinafter “AgroWest”) appeal from an order granting a new trial to plaintiffs David and Carolyn Sheets (hereinafter “Sheets”) to redetermine the comparative negligence of the parties and the amount of damages for personal injury. Agro-West argues that we should alter the standard of review for new trial motions; that the broad trial court’s discretion to order a new trial — subject only to review for manifest abuse of discretion— violates the right to jury trial guaranteed by our state and federal constitutions; and that, in any event, the trial court abused its discretion in granting a new trial. We reject these arguments and affirm the order of the trial court granting a new trial.

Agro-West is a commercial distributor of farm chemicals. On June 22,1978, a chemical spill occurred at Agro-West’s facility near Wilder, Idaho. The chemical spilled was Terr-o-cide 30-D. In response to a request from Layton Noe, manager of Agro-West, Idaho Concrete and Pipe Company dispatched its employee, David Sheets, to deliver a load of road mix — a mixture of sand, gravel and dirt — to be spread on the spill. While spreading the mix, Sheets drove his truck through the spill and immediately began experiencing physical reactions from exposure to the fumes of the chemical. His eyes watered, he began coughing and had difficulty breathing. He was able to stop his truck and escape the fumes before passing out. Since that time, he has complained of, and has been treated for, a number of physical ailments and discomforts allegedly caused by the incident.

Sheets and his wife brought suit in negligence for damages against Agro-West and Noe. By special verdict, the jury found Sheets eighty-seven percent negligent, found Agro-West and Noe thirteen percent negligent, and made an award of damages to Sheets. Because a plaintiff suing for negligence in Idaho cannot recover damages where his negligence equals or exceeds that of the defendant, I.C. § 6-801, the jury’s assessment of negligence precluded recovery of damages by Sheets.

Sheets moved for a new trial. The court granted Sheets’ motion, citing I.R.C.P. 59(a)(5) and 59(a)(6). Under Rule 59(a)(5), a new trial may be granted because of excessive or inadequate damages, appearing to have been given under the influence of passion or prejudice. Under Rule 59(a)(6), a new trial may be granted because of the [883]*883insufficiency of the evidence to justify the verdict or other decision, or that it is against the law.

We will first consider Agro-West’s contention that a new standard should be applied to review a trial court’s grant of a new trial. The present standard of review is that “the determination of a new trial motion is largely within the discretion of the trial court and [the appellate court] will not overrule the grant or denial of the motion absent a manifest abuse of discretion.” Rowett v. Kelly Canyon Ski Hill, Inc., 102 Idaho 708, 709, 639 P.2d 6, 7 (1981). This standard has, as its foundation, the premise that the trial judge has had the opportunity to observe the parties, witnesses, and counsel during the trial and can better judge whether a fair trial was had and substantial justice was done. Rowett, supra, 102 Idaho at 710, 639 P.2d at 8.

The standard which Agro-West urges upon us is the “substantial evidence” standard which our Supreme Court has applied to motions for judgment n.o.v. “[A] motion for judgment n.o.v. should not be granted when there is substantial competent evidence to support the verdict of the jury.” Mann v. Safeway Stores, Inc., 95 Idaho 732, 735, 518 P.2d 1194, 1197 (1974). Agro-West bases its argument for a different standard on the increase in time, monetary expense, and uncertainty which results from the grant of a second trial. It argues that the substantial rights of the prevailing litigants are ignored and fundamental unfairness results when a new trial is ordered. AgroWest cites Lind v. Schenley Industries, Inc., 278 F.2d 79 (3rd Cir.1960), cert. denied, 364 U.S. 835, 81 S.Ct. 58, 5 L.Ed.2d 60 (1960), as authority for the proposition that “closer appellate scrutiny” is required where a new trial is granted on the basis that a jury’s verdict is against the weight of the evidence. The implication is that closer appellate scrutiny means a higher standard to be applied in reviewing a grant of a new trial motion.

However, we note that in Mann the Idaho Supreme Court explicitly considered and rejected the application of the “substantial evidence” standard to new trial motions. In Mann, the court reaffirmed its' support for the rule permitting the trial court to exercise its discretion in deciding new trial motions. 95 Idaho at 736, 518 P.2d at 1198; see also Dinneen v. Finch, 100 Idaho 620, 626, 603 P.2d 575, 581 (1979).

A motion for new trial serves a function entirely distinct from a motion for judgment n.o.v. C. Wright & A. Miller, Federal Practice and Procedure, Civil § 2531. A judgment n.o.v. is recognized as “a delayed motion for directed verdict.” Mann, 95 Idaho at 736, 518 P.2d at 1198. A directed verdict should be granted only when the evidence is so clear and undisputed that all reasonable minds must reach the same conclusion. Shields & Co., Inc. v. Green, 100 Idaho 879, 606 P.2d 983 (1980); Lombard v. Cory, 95 Idaho 868, 522 P.2d 581 (1974). A directed verdict or judgment n.o.v. is grounded on the principle that, while issues of fact are for the jury to decide, whether the evidence is sufficient to create an issue of fact is a question of law for the court. Wright & Miller, supra, Civil § 2524.

A motion for new trial, if granted, does not result in an adjudication of factual issues by the court. Neither does it represent a determination that, as a matter of law, the evidence failed to establish an issue of fact. It is the court’s statement that it believes the jury erred in its findings or in the application of law as contained in the court’s instructions, and that the issues should be submitted to another jury for redetermination. Because a jury will still determine the factual issues, the standard for granting a new trial is much less rigorous than that applied to motions for directed verdict or judgment n.o.v. Wright & Miller, supra, Civil § 2531. A motion for new trial should be granted if the court believes that the jury verdict “is not in accord with law or justice.” Seppi v. Betty, 99 Idaho 186, 189, 579 P.2d 683, 686 (1978), quoting Warren v. Eshelman, 88 Idaho 496, 500, 401 P.2d 539, 541 (1965). Implicit in this statement is the recognition that where reasonable minds could disagree, but the [884]*884trial court believes the jury verdict is in error, the benefit of arriving at a legally correct and just resolution of a dispute through a new trial outweighs the disadvantage of uncertainty, time and expense incident to continued litigation.

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Bluebook (online)
664 P.2d 787, 104 Idaho 880, 1983 Ida. App. LEXIS 228, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheets-v-agro-west-inc-idahoctapp-1983.