Illinois Court Denies Plaintiff’s Request to Change Theory of Liability in Product Defect Lawsuit – Aldridge v. Forest River, Inc.

The U.S. Court of Appeals for the Seventh Circuit affirmed a lower court’s ruling regarding the plaintiff’s request to amend its complaint. In Linda Aldridge v. Forest River, Inc., et al., 10-2193, the plaintiff sought to add an additional theory of liability onto her original complaint. While this is not typically against judicial procedures, the plaintiff attempted to amend her complaint at the onset of her product defect trial. The court denied her request because doing so would have changed the plaintiff’s theory of liability, which would have drastically affected the way the product liability case was tried.

The plaintiff’s original product defect claims arose out of an incident with her Forest River recreational vehicle (RV). As the plaintiff, Linda Aldridge, was exiting her RV, the steps unexpectedly retracted back into the vehicle, causing Aldridge to fall and injure her shoulder. In her original complaint, Aldridge alleged that her injury was a result of Forest River’s defective step controller.

The Illinois product liability complaint alleged that the step controller’s unexpected retraction was the cause of Aldridge’s fall. Counts I and III were based on strict liability, stating that the RV step controller was not reasonably safe for its intended use, which was to raise and lower the RV’s steps. Furthermore, the complaint alleged that Forest River had failed to properly wire, install, and test the step controller.

While the original complaint dealt only with the defective RV steps, Aldridge’s proposed amended complaint would also include allegations that the whole RV was defective. This amendment would change Aldridge’s theory of liability from allegations that her fall was a result of a defective stair-step controller, to allegations that her fall was a the result of a defective RV.

The defendants brought a motion in limine seeking to prevent Aldridge from filing her amended complaint. In its motion, the defendants argued that the amended complaint would raise a new theory of liability, which would unfairly burden the RV’s ability to defend itself at trial. The district court held that Aldridge had maintained throughout the case that the step controller was the product on which her product liability lawsuit was based. The court went on to say that to allow the case to be tried in a different fashion, now alleging that the product as a whole was defective, would be to changing the theory of the case.

Undeterred by the court’s granting of the defendant’s motion in limine, Aldridge filed her own motion that would allow her to amend the Illinois product liability complaint to allege that the entire recreational vehicle was not reasonably safe for its intended use. The court denied that motion based on the same reasons for granting the motion in limine:

(1) the plaintiff had identified the product as the step controller; (2) the defendants had litigated the case with the understanding that the product forming the basis of the complaint was the step controller; and (3) that the defendants would not have time to prepare a meaningful defense at a late stage in these proceedings.

The purpose of a complaint is to lay out the plaintiff’s theory of liability and give the defendants an opportunity to respond and defend itself. The discovery process is meant to give both sides an opportunity to collect their evidence and respond to the other side’s arguments. By the time trial approaches there should be no new evidence or theories introduced; this helps prevent one side from withholding information, or from using the element of surprise to handicap the opposing side. This ensures that the jury decides the case based on facts alone and that both parties are afforded a fair trial. However, if the theory of liability is changed immediately before trial then this does not give the other party adequate time to adjust their argument and defense, which could lead to an unfair trial.

After the jury returned a verdict in favor of the defendants, the plaintiff appealed the district court’s decisions regarding her alternate theory of liability. Aldridge argued that the court’s denial of her motion to amend her complaint resulted in a negative verdict and that the case should be retried with the altered theory of liability. However, the Court of Appeals agreed with the district court’s decisions, stating that the decision of whether or not plaintiff could amend her complaint was up to the trial judge. The appellate court affirmed that the trial judge had acted within his discretion by denying the plaintiff’s motion because the plaintiff had repeatedly stated that the step controller alone, and not the RV as a whole, was the proximate cause of her injuries. It was only immediately prior to the product defect trial that plaintiff sought to alter her theory of liability.

Furthermore, the Court of Appeals cited the defendants’ lack of consent to amending the theory of liability as further support of the trial judge’s decision. Again, the amended complaint would have added a new theory of liability to the product defect lawsuit at the final stage of the proceedings, which would have placed an undue burden on the defendants. Therefore, the Seventh Circuit of Appeals affirmed the district court’s decisions and letting the jury verdict in favor of the defendants stand.

Kreisman Law Offices has been handling Illinois product defect cases for more than 35 years in and around Chicago, Cook County, and surrounding areas, including Park Forest, Lincolnwood, Des Plaines, Streamwood and Joliet.

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