Wurm v. Ford Motor Company

CourtCourt of Appeals for the Tenth Circuit
DecidedApril 13, 2021
Docket20-3126
StatusUnpublished

This text of Wurm v. Ford Motor Company (Wurm v. Ford Motor Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wurm v. Ford Motor Company, (10th Cir. 2021).

Opinion

FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT April 13, 2021 _________________________________ Christopher M. Wolpert MATTHEW WURM, Clerk of Court

Plaintiff - Appellant, No. 20-3126 v. (D.C. No. 2:18-CV-02322-HLT) (D. Kan.) FORD MOTOR COMPANY,

Defendant - Appellee. _________________________________

ORDER AND JUDGMENT * _________________________________

Before HOLMES, BACHARACH, and MCHUGH, Circuit Judges. _________________________________

This is a product liability case. Mr. Matthew Wurm was riding in a

Ford truck when it crashed and rolled over, resulting in serious injuries. He

sued Ford for a design defect and proffered testimony by two expert

witnesses. One expert attributed the injuries to a crushed roof, and the

other expert concluded that the truck’s roof had been defectively designed.

* Because oral argument would not materially help us decide the appeal, we base our decision on the briefs and appendix. See Fed. R. App. P. 34(a)(2)(C); 10th Cir. R. 34.1(G).

This order and judgment does not constitute binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel. But the order and judgment may be cited for its persuasive value if otherwise appropriate. Fed. R. App. P. 32.1(a); 10th Cir. R. 32.1(A). In response, Ford denied a design defect, arguing that the force of the

collision had caused Mr. Wurm to “dive” into the roof, which led to his

injuries. Based on this argument, Ford moved for exclusion of the expert

testimony and an award of summary judgment. The district court granted

both motions.

Mr. Wurm challenges the rulings, and we affirm. Mr. Wurm hasn’t

adequately developed an argument that either ruling was wrong. Even

without such an argument, however, we have independently reviewed the

rulings and detect no error.

1. Mr. Wurm proffered opinion testimony by two expert witnesses, and the district court excluded both.

To support his allegations, Mr. Wurm retained two expert witnesses:

Shawn Parcells and David McLellan. Ford moved to exclude their opinion

testimony based on inadequate qualifications.

First, Mr. Wurm proffered expert testimony by Mr. Parcells, who had

participated in autopsies while working as a pathology assistant; Mr.

Parcells was to testify that Mr. Wurm’s injuries had been consistent with a

“roof crush” injury (caused by a design defect) rather than a “dive” injury

(caused by the driver’s or passenger’s negligence). This testimony called

for expertise in the cause of injury (biomechanics), reconstruction of Mr.

Wurm’s movements after the crash (occupant kinematics), and the risk of

injury in an auto accident (epidemiology). The district court excluded Mr.

2 Parcells’s testimony, reasoning that he lacked the qualifications required

for expert opinions in these fields.

Second, Mr. Wurm proffered expert testimony by Mr. McLellan, a

mechanical engineer who had worked as a chief engineer at General

Motors. He was to testify about a design defect in the truck’s roof. The

district court concluded that Mr. McLellan had lacked the required

qualifications and used an unreliable methodology.

Though Mr. McLellan had expertise in car design, the district court

found that he lacked expertise on truck design, vehicle roof design, or

rollover testing. The court also questioned his methodology. Mr. McLellan

had relied on a 2005 Exponent Roof Crush Test performed on a later model

of the truck, which contained a cab that was longer than the cab on the

truck involved in the accident.

Mr. McLellan observed that the truck at issue and the trucks being

tested had collapsed into similar V shapes. But Mr. McLellan did not

explain how or why the V-shaped collapses had proven design defects. Nor

could he compare the force involved in Mr. Wurm’s crash with the force

involved in the tests.

Based on the lack of relevant qualifications and a reliable

methodology, the district court excluded Mr. McLellan’s testimony.

3 2. The district court awarded summary judgment to Ford.

With exclusion of both expert witnesses, Mr. Wurm lacked any

evidence of causation or a design defect. With no such evidence, he

conceded that the expert testimony was “integral to any possibility of

recovery.” Appellant’s App’x vol. X, at 1242. The district court thus

granted summary judgment to Ford.

3. Mr. Wurm waived an appellate challenge based on inadequate briefing in his opening brief.

An opening brief must identify the “appellant’s contentions and the

reasons for them, with citations to the authorities and parts of the record

on which the appellant relies.” Fed. R. App. P. 28(a)(8)(A). Issues not

raised or inadequately presented in an appellant’s opening brief are

considered waived. See Burke v. Regalado, 935 F.3d 960, 1014 (10th Cir.

2019).

In his opening brief, Mr. Wurm does not explain how the district

court erred in excluding the two expert witnesses or in granting summary

judgment. In a “statement of applicable law,” Mr. Wurm asserts eight legal

propositions:

1. A “pattern of injury” should be considered a viable method to prove the mechanics of an injury.

2. In another case, a court allowed opinion testimony from an expert witness who had experience in “forensic biomechanics occupant kinematics.”

4 3. Expert testimony must be relevant and reliable.

4. Expert witnesses should not be allowed to testify if they lack qualifications in the relevant field.

5. Kansas’s pattern jury instructions provide that when two expert witnesses have the required expertise but differ in their credentials, the jury should be allowed to weigh the expert testimony.

6. Under Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), an expert witness can testify regarding an alternative design without constructing a model.

7. A duty to warn may arise after the sale took place.

8. An expert opinion on causation need not involve a “scientific absolute.”

Appellant’s Opening Br. at 7–11. Mr. Wurm then provides a factual

statement, recites the standard of review, and says how a defective

condition can be proven under Kansas law.

Though Mr. Wurm asserts eight legal propositions, provides a factual

statement, recites the standard of review, and says how he could prove a

defective condition, he never states in his opening brief how the district

court erred in excluding the two expert witnesses or in granting summary

judgment. He thus waived all issues in his opening brief.

4. Mr. Wurm’s new arguments in his reply brief are too late and inadequately developed.

In his reply brief, Mr. Wurm

 argues that the exclusion of the expert testimony violated his Seventh Amendment right to a jury trial and

5  urges application of the purported “gimlet eye test” from Lee v. Max International, LLC, 638 F.3d 1318 (10th Cir. 2011).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
Coletti v. Cudd Pressure Control
165 F.3d 767 (Tenth Circuit, 1999)
Ralston v. Smith & Nephew Richards, Inc.
275 F.3d 965 (Tenth Circuit, 2001)
Jewell v. Life Insurance Co. of North America
508 F.3d 1303 (Tenth Circuit, 2007)
Lee v. Max Intern., LLC
638 F.3d 1318 (Tenth Circuit, 2011)
Ho v. Michelin North America, Inc.
520 F. App'x 658 (Tenth Circuit, 2013)
Planned Parenthood KS & Mid-MO v. Brownback
747 F.3d 814 (Tenth Circuit, 2014)
Anderson v. Spirit AeroSystems Holdings, Inc.
827 F.3d 1229 (Tenth Circuit, 2016)
Margheim v. Buljko
855 F.3d 1077 (Tenth Circuit, 2017)
United States v. Tee
881 F.3d 1258 (Tenth Circuit, 2018)
United States v. Walker
918 F.3d 1134 (Tenth Circuit, 2019)
Burke v. Regalado
935 F.3d 960 (Tenth Circuit, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Wurm v. Ford Motor Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wurm-v-ford-motor-company-ca10-2021.