[DO NOT PUBLISH]
IN THE UNITED STATES COURT OF APPEALS
FOR THE ELEVENTH CIRCUIT FILED
________________________ U.S. COURT OF APPEALS
ELEVENTH CIRCUIT
AUGUST 5, 2010
No. 08-16182
JOHN LEY
________________________
CLERK
D. C. Docket No. 04-00106-CV-RWS-2
GARLAND REYNOLDS, JR.,
As Administrator of the Estate of
Matthew John Reynolds,
BONNIE J. REYNOLDS,
as Surviving Parent of Matthew John
Reynolds,
GARLAND REYNOLDS, JR.,
as Surviving Parent of Matthew John
Reynolds,
GARLAND REYNOLDS, JR.,
Individually and as Husband of Bonnie
J. Reynolds,
BONNIE J. REYNOLDS,
Individually,
Plaintiffs-Appellees,
versus
GENERAL MOTORS CORPORATION,
a Foreign Corporation,
Defendant-Appellant,
________________________
Appeal from the United States District Court
for the Northern District of Georgia
_________________________
(August 5, 2010)
Before DUBINA, Chief Judge, PRYOR and MARTIN, Circuit Judges.
PER CURIAM:
After a jury verdict for the Reynolds in a products liability case arising out
of a rollover in a 1995 Chevrolet Blazer, General Motors Corporation (“GM”)
appealed.
The issues presented on appeal are:
(1) Whether the district court erred by instructing the jury on
crashworthiness.
(2) Whether the district court erred in denying GM’s motion for judgment as
a matter of law on the plaintiffs’ stability claim.
(3) Whether the district court erred in denying GM’s motion for judgment as
a matter of law on the plaintiffs’ failure-to-warn claim.
(4) Whether the district court abused its discretion by excluding evidence of
seatbelt nonuse.
(5) Whether the district court abused its discretion by admitting a video
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showing driving tests.
(6) Whether the district court abused its discretion by excluding video clips
of, and prohibiting cross-examination regarding, other driving tests conducted by
the same driver.
Several standards of review govern this appeal. Although we review jury
instructions de novo to determine whether they misstate the law or mislead the jury
to the prejudice of the objecting party, the district court is afforded wide discretion
with respect to the instructions’ style and wording as long as the instructions
accurately reflect the law. See Morgan v. Family Dollar Stores, Inc., 551 F.3d
1233, 1283 (11th Cir. 2008). We review de novo a district court’s decision to deny
a Rule 50 motion for judgment as a matter of law and to instead submit the issue to
a jury. See Abel v. Dubberly, 210 F.3d 1334, 1337 (11th Cir. 2000). A district
court’s evidentiary rulings are reviewed for abuse of discretion. See United States
v. Henderson, 409 F.3d 1293, 1297 (11th Cir. 2005).
After reading the parties’ briefs, reviewing the record, and having the benefit
of oral argument, we affirm. The crashworthiness instruction was an accurate
statement of Georgia law, and the instruction was not so misleading as to prejudice
GM. In light of the evidence presented at trial, the district court did not err in
submitting the stability and failure-to-warn claims to the jury.
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With respect to the claimed evidentiary errors, we are not persuaded that any
of the challenged decisions amounted to an abuse of discretion. The exclusion of
seatbelt nonuse was consistent with O.C.G.A. § 40-8-76.1 and due process. GM
has not carried its burden of showing that there was no competent evidence to
support the district court’s determination that the test video was properly
authenticated. Finally, the district court properly exercised its discretion in
excluding evidence related to the tipping of other vehicles, because the
introduction of such evidence likely would have led to extensive discussion of
collateral matters and confused the jury.
For the foregoing reasons, the judgment of the district court is
AFFIRMED.
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