ST. LOUIS — The Missouri Court of Appeals ruled that a lower court abused its discretion by failing to grant a mistrial involving Stanley Fastening Systems.
Stanley Fastening Systems appealed a jury verdict favoring Andrew Wilkinson in a products liability case where Wilkinson suffered a severe eye injury from a Stanley pneumatic stapler, according to an opinion filed July 16 in the Missouri Court of Appeals Eastern District.
The incident occurred when Wilkinson, a contractor, was handling a stapler, and it accidentally fired a staple into his eye, leading to its surgical removal.
Wilkinson sued Stanley, alleging negligence in the design and failure to warn about the stapler's safety features.
During the trial, Stanley objected to Wilkinson's counsel repeatedly referring to Stanley as a "billion-dollar company," which violated a pre-trial order barring discussions of Stanley's financial status.
Despite objections, the trial court did not grant Stanley's request for a mistrial, and the jury ultimately awarded Wilkinson $11 million in noneconomic damages.
Stanley's appeal focused on denying a mistrial, arguing that the improper references to its wealth were highly prejudicial and influenced the jury's excessive damages award.
Missouri law and court precedents prohibit introducing a party's financial status to sway jury sympathy or bias, emphasizing fair trials based on evidence rather than financial disparities, the opinion states.
The appellate court reviewed whether the trial court's decision not to declare a mistrial constituted an abuse of discretion. It found that Wilkinson's counsel's repeated references to Stanley's financial status were flagrant violations of the court's order and legal guidelines. Such references are known to improperly influence jury deliberations, potentially prejudicing the jury against the defendant, the opinion states.
Missouri courts have overturned verdicts or granted mistrials in cases where such improper references occurred, as they undermine the integrity of the trial process and can lead to biased outcomes.
The court cited cases where similar errors led to mistrial rulings, reinforcing the principle that even sustained objections and admonitions to disregard such remarks may not fully undo their prejudicial impact.
The size of the damages awarded by the jury—$11 million—further underscored the potential influence of these improper statements.
Although large awards alone do not necessarily indicate prejudice, in conjunction with improper statements, they raise concerns about whether the jury was unduly influenced by factors outside the scope of the case's merits.
Wilkinson argued that the references to Stanley's financial status were relevant to the issue of record retention in the loan tool program, but the court rejected this justification. It concluded that such arguments could have been pursued without invoking Stanley's wealth, which served no purpose but to improperly sway the jury's perception.
The appellate court agreed with Stanley that the trial court erred in not granting a mistrial.
The repeated and deliberate nature of Wilkinson's counsel's remarks, coupled with their potential to bias the jury, warranted corrective action beyond sustained objections.
Therefore, the court reversed the original judgment and ordered a new trial, emphasizing the need to uphold fair trial practices and prevent undue influence on jury decisions.
The appellant was represented by David L. Coffman, Booker T. Shaw and Benjamin S. Harner. The respondent was represented by David Grebel, Mark R. Niemeyer and Michael S. Kruse.
Attorneys declined to comment further on the decision.
Missouri Court of Appeals Eastern District case number: ED111901