Vicky Church, Sarah Austin and Jacob Church, on behalf of all Beneficiaries v. CNH Industrial America, LLC

CourtMissouri Court of Appeals
DecidedMay 16, 2023
DocketWD85103
StatusPublished

This text of Vicky Church, Sarah Austin and Jacob Church, on behalf of all Beneficiaries v. CNH Industrial America, LLC (Vicky Church, Sarah Austin and Jacob Church, on behalf of all Beneficiaries v. CNH Industrial America, LLC) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vicky Church, Sarah Austin and Jacob Church, on behalf of all Beneficiaries v. CNH Industrial America, LLC, (Mo. Ct. App. 2023).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT VICKY CHURCH, SARAH AUSTIN ) AND JACOB CHURCH, ON BEHALF ) OF ALL BENEFICIARIES, ) ) Respondents, ) ) v. ) WD85103 ) CNH INDUSTRIAL AMERICA, LLC, ) Opinion filed: May 16, 2023 ) Appellant. )

APPEAL FROM THE CIRCUIT COURT OF HENRY COUNTY, MISSOURI THE HONORABLE JAMES K. JOURNEY, JUDGE

Division Three: Janet Sutton, Presiding Judge, Cindy L. Martin, Judge and Edward R. Ardini, Jr., Judge

CNH Industrial America, LLC (“CNH”) appeals from the judgment of the Circuit

Court of Henry County awarding damages to Vicky Church, Sarah Jo Austin, Jacob

Church, Norman Church, and Irene Church (collectively, “Plaintiffs”) in their wrongful

death suit against CNH alleging strict products liability and negligence following the death

of Wayne Church (“Church”). Church, a mechanic, was crushed while repairing a CNH-

manufactured skid steer. CNH argues the trial court erred in rejecting its proffered

comparative fault instruction, erred in permitting evidence of three other cab-closure incidents involving CNH-manufactured products, erred in permitting Plaintiffs’ expert to

testify about liability and causation, and erred in its award of post-judgment interest. We

affirm in part and reverse in part.

Factual and Procedural Background

In March 2016, Church, an experienced mechanic, was hired to work on the

hydraulics of a CNH Model 60XT skid steer owned by Cody Peery (“Peery”). While

working on the skid steer, Church was crushed when the cab fell and trapped him beneath.

No one was present at the time of the accident, but Church was able to call 911 from his

cell phone. When emergency responders arrived, a single paramedic lifted the cab off of

Church. After Church had been removed, the cab remained raised for a short time and then

fell on its own. Church was transported to a hospital where he died from his injuries.

Plaintiffs filed a wrongful death action against CNH, alleging strict products

liability (failure to warn and instruct; design defect) and negligence. Specifically, Plaintiffs

claimed that the skid steer had a defective design, that CNH failed to warn users that the

latch that held open the cab when undergoing maintenance (the hold-open latch) could

easily break without the user’s knowledge, and that a broken latch would permit the cab to

abruptly close. A jury trial was held at which the following evidence was adduced:

In the early 2000s, CNH designed and manufactured skid steers with a new design

for holding the cab open during maintenance. This design consisted of a cantilever and a

hold-open latch, which allowed the user to pull the cab open until the hold-open latch

engaged. The hold-open latch was not designed to support the weight of the cab; instead,

when the cab was fully opened, gravity kept the cab from closing. The hold-open latch was

2 designed to engage before the cab could inadvertently close due to external forces such as

wind or a mechanic bumping the cab.

The skid steer relevant to this case was outfitted with a hold-open latch which was

broken at the time of the accident. According to CNH’s expert, pushing on the grab handles,

including for the purpose of confirming that the latch was engaged, could create enough

force to break the latch. CNH acknowledged that a strong gust of wind could close the cab

if the hold-open latch was not operational. Photographs of a properly functioning hold-

open latch revealed no perceptive difference from a broken latch. Despite knowing of the

fragility of the hold-open latch, CNH did not warn users of the associated danger.

According to Plaintiffs’ expert, Russ Rasnic, Church fully opened the cab and began

working on the skid steer’s hydraulics. At some point, as a result of the hold-open latch

being inoperative, either a strong wind or the cab being bumped caused the cab to close,

trapping Church and ultimately leading to his death. Rasnic opined that the hold-open latch

was defectively designed causing it to break under normal use, an inoperative hold-open

latch was not readily apparent to a user, and CNH provided no warning that the latch could

break rendering an opened cab unsecure and at risk of closing.

In contrast, CNH’s experts opined that the cab on this particular skid steer was too

heavy for a single person to lift because one of the struts that assists in lifting the cab was

depleted of nitrogen, which would have made it more difficult to raise. CNH’s experts

believed that Church used three-foot pry bars, which were found on the ground near the

skid steer following the accident, to help keep the cab open. One of the experts testified

that Church’s injuries were more consistent with a cab falling from a partially opened

3 position, which could have been achieved using the pry bars. Therefore, CNH argued that

Church had misused the skid steer. CNH also asserted that Peery knew that the latch was

broken and had informed Church that he had previously experienced difficulty opening the

cab and had needed to tie the cab in an open position to perform maintenance on the skid

steer. Thus, CNH asserted that Church should have known that the latch was broken and

should have taken protective measures such as tying the cab open.

The jury returned a verdict in favor of Plaintiffs, awarding $3,000,000 in

compensatory damages and $10,000,000 in punitive damages. On November 17, 2020, the

trial court entered a judgment on the verdict and awarded Plaintiffs post-judgment interest.

CNH appealed, which was dismissed by this Court because the trial court had failed to

apportion the damages among the beneficiaries and thus the judgment was not yet final.

On November 23, 2021, the trial court entered a judgment apportioning the compensatory

and punitive damages and awarding post-judgment interest as of the date of the original

November 2020 judgment. CNH appeals. Additional facts will be recited throughout this

opinion.

Discussion

CNH raises four points on appeal. In its first point, CNH alleges that the trial court

erred in refusing to submit a comparative fault instruction to the jury. In Point II, CNH

claims that the trial court erred in allowing evidence of three other incidents involving hold-

open latches to be presented to the jury. In its third point, CNH asserts that the trial court

erred in permitting Rasnic, Plaintiffs’ expert, to testify about liability and causation.

Finally, in Point IV, CNH argues that the trial court erred in awarding post-judgment

4 interest from the earlier, non-final judgment instead of the judgment later entered after

damages had been apportioned.

Point I – Instructional Error

In Point I, CNH asserts that the trial court erred by refusing to submit a proffered

comparative fault instruction, arguing that “sufficient evidence exists to support

submission of the instruction in that both parties adduced evidence regarding Wayne

Church’s actions and whether his conduct caused or contributed to cause his death,

including whether he failed to follow the manufacturer’s instructions to fully open the cab

and ensure the hold open latch is engaged before undertaking maintenance on the machine,

failing to inspect the condition of the 60XT, or adhere to the warning and instructions

provided by Peery, and instead used pry bars found at the scene to only partially open the

cab.”

Facts

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Vicky Church, Sarah Austin and Jacob Church, on behalf of all Beneficiaries v. CNH Industrial America, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vicky-church-sarah-austin-and-jacob-church-on-behalf-of-all-beneficiaries-moctapp-2023.