Law
A homeowner who suffered the destruction of her home by fire properly filed a products liability action against the manufacturer of her toaster in federal district court. Under the applicable state law, a product defect must be proven in order to establish a products liability cause of action. Mere proof of a malfunction is not sufficient by itself to establish a product defect. At the close of the homeowner's presentation of her case to the jury, the manufacturer moved for judgment as a matter of law because the homeowner had failed to establish that there was a defect with respect to the toaster. The homeowner opposed this motion. The court determined, viewing the evidence in the light most favorable to the homeowner, that the homeowner had established by a preponderance of the evidence both that the toaster was the source of the fire and that the toaster had malfunctioned.Should the court grant the manufacturer's motion?Yes, because the homeowner failed to prove that there was a defect with respect to the toaster.Under Rule 50(a), once a party has been fully heard on an issue at a jury trial, the court may grant a motion for judgment as a matter of law resolving the issue against a party if the court finds that there is insufficient evidence for a jury reasonably to find for that party. Because the homeowner failed to present sufficient evidence to establish that there was a defect with respect to the toaster, which is a necessary element of a products liability action under the applicable state law, the court should grant the manufacturer's motion for a judgment as a matter of law. Answer choice B is incorrect because the court does not have broad discretion to grant a motion for judgment as a matter of law. If, after viewing all evidence and drawing all inferences in favor of the non-moving party, reasonable people could reach different conclusions, the motion cannot be granted. Answer choice C is incorrect because, even though the court, by viewing the evidence in the light most favorable to the homeowner (i.e., the party opposing the motion), was applying the correct standard in assessing the evidence, the court's determination that the homeowner established that the toaster had malfunctioned is not sufficient for the homeowner to avoid judgment as a matter of law. Under the applicable state law, mere proof that a product malfunctioned is not sufficient to establish that there was product defect, which is a necessary element of the homeowner's products liability cause of action.