Spurlin v. General Motors Corp.

Spurlin v. General Motors Corp., 528 F.2d 612 (5th Cir. 1976), is the most-cited court decision with "Spurlin" in its name. CourtListener shows it cited by more than 70 opinions.^[1][2][3] The lead plaintiff, A. A. Spurlin, sued as the surviving parent of Douglas J. Spurlin, a child who died in the crash.^[1]

Facts

On April 23, 1968, the brakes failed on a school bus in Morgan County, Alabama, and it crashed.^[1] Two wrongful-death suits and twenty-two personal-injury actions were filed on behalf of the children on board against General Motors, which made the bus chassis.^[1] The plaintiffs argued that the 1965 66-passenger bus was not reasonably safe. It had a single hydraulic brake system that would fail completely if its one fluid reservoir leaked, no real emergency brake (only a parking brake), and no warning device for low brake fluid. They also argued that the owner's manual called for brake-fluid checks too rarely.^[1]

Procedural history

In an earlier interlocutory appeal, 426 F.2d 294 (1970), the Fifth Circuit declined to rule on the "currently much mooted 'crashworthy' concept." That claim alleged that the bus top collapsed when the bus overturned after leaving the road. The trial court had granted summary judgment to the bus-body maker, Thomas, apparently following the Seventh Circuit's approach in Evans v. General Motors rather than the Eighth Circuit's in Larsen v. General Motors. The appeals court vacated its own order allowing the appeal, saying such a question needed a full factual record.^[4] The cases were consolidated for trial, and a six-person jury heard about two weeks of evidence. The judge sent the case to the jury only on negligent design of the braking system, refusing instructions on negligent manufacture and on strict liability in tort. The jury found for the plaintiffs and awarded $70,000 in each wrongful-death case.^[1] Those two claims were brought under the Alabama Homicide Act, under which, as the opinion notes, damages are punitive rather than compensatory.^[1] The district court then granted GM's motions for judgment notwithstanding the verdict (JNOV) and, in the alternative, for a new trial.^[1]

Holding

Writing for the panel, Judge Elbert Tuttle applied the Fifth Circuit's en banc standard from Boeing Co. v. Shipman. Under that test, the court must view all the evidence in the light most favorable to the non-moving party, and the case belongs to the jury if reasonable people could reach different conclusions.^[1] The court found the evidence "more than sufficient" to survive JNOV. That evidence included expert testimony that the single system was unsafe, proof that dual hydraulic systems were in use on large buses in England and Europe before 1964, and GM's own testimony that fail-safe air brakes were optional on that chassis.^[1] The court also found that the verdict was not against the great weight of the evidence. It reversed both rulings and directed judgment on the verdict for the plaintiffs.^[1] Rehearing and rehearing en banc were denied on May 10, 1976.^[1]

Significance

Law students know the case mainly as an illustration of when a judge may take a verdict away from a jury. One commercial case-brief service lists it under "Judgment notwithstanding the verdict" in materials keyed to the Hazard civil procedure casebook, summing up its rule as: when reasonable people could differ on the proper verdict, the matter goes to the jury and JNOV is improper.^[5] Quimbee, another commercial study aid, also publishes a brief of the case. Its free summary describes the claims of negligent brake design and inadequate servicing instructions.^[6]