Tran v. Toyota Motor Corp.

66 Citing cases

  1. Mitsubishi Motors v. Laliberte

    No. 4D08-2211 (Fla. Dist. Ct. App. Jun. 16, 2010)

    However, "`[a]n abuse of discretion can occur where the district court applies the wrong law, follows the wrong procedure, bases its decision on clearly erroneous facts, or commits a clear error in judgment.'" Tran v. Toyota Motor Corp., 420 F.3d 1310, 1315 (11th Cir. 2005) (quoting United States. v. Brown, 415 F.3d 1257, 1266 (11th Cir. 2005)). This case presents a unique question: Whether the trial court abused its discretion by incorrectly applying the doctrine of substantial similarity to test whether Mitsubishi's demonstrative evidence was relevant to the issues in the case.

  2. Tillman v. C.R. Bard, Inc.

    Case No. 3:13-cv-222-J-34JBT (E.D. Cal. Mar. 30, 2015)

    Although Florida courts generally continue to rely on the consumer-expectation test, some courts have observed that "there may . . . be products that are too complex for a logical application of the consumer-expectation standard." See Force, 879 So. 2d at 106; Tran v. Toyota Motor Corp., 420 F.3d 1310, 1314 (11th Cir. 2005). At least one District Court of Appeal in Florida has rejected the consumer-expectation test entirely.

  3. Tillman v. C.R. Bard, Inc.

    96 F. Supp. 3d 1307 (M.D. Fla. 2015)   Cited 52 times
    In Tillman, the Middle District of Florida relied on guidance from the Sixth Circuit that “[t]he best resolution of this type of problem is to determine whether the terms used by the witness have a separate, distinct and specialized meaning in the law different from that present in the vernacular.

    Although Florida courts generally continue to rely on the consumer-expectation test, some courts have observed that “there may ... be products that are too complex for a logical application of the consumer-expectation standard.” See Force, 879 So.2d at 106 ; Tran v. Toyota Motor Corp., 420 F.3d 1310, 1314 (11th Cir.2005). At least one District Court of Appeal in Florida has rejected the consumer-expectation test entirely.

  4. Abbott Point of Care, Inc. v. Epocal, Inc.

    868 F. Supp. 2d 1310 (N.D. Ala. 2012)   Cited 12 times
    Finding that although a defendant's own patent cannot be a defense to patent infringement, it is relevant to claims of willfulness

    The district court has broad discretion in controlling the evidence presented at trial, including the decision whether to exclude cumulative evidence. Tran v. Toyota Motor Corp., 420 F.3d 1310, 1315 (11th Cir.2005). If the qualifications and proposed testimony of Dr. Wickramasinghe and Dr. Olbricht were exactly identical, as Abbott suggests, the court would not allow both witnesses to testify, because doing so would waste its own time and that of the jury.

  5. Mitsubishi Motors Corp. v. Laliberte

    52 So. 3d 31 (Fla. Dist. Ct. App. 2010)   Cited 2 times
    Noting that, although plaintiffs relied heavily on similarity analysis, trial court's “ultimate evidentiary rulings” were based on relevance and prejudice, among other grounds

    Generally, the doctrine of substantial similarity applies in products liability claims when a party attempts to introduce evidence of prior accidents, to recreate the accident involving the defendant's product, to show notice of defect, magnitude of the danger involved, the defendant's ability to correct a known defect, or the lack of safety for intended uses. See Tran v. Toyota Motor Corp., 420 F.3d 1310, 1316 (11th Cir. 2005). Here, Mitsubishi admittedly did not attempt to recreate the accident.

  6. Mchale v. Rown Equip. Corp.

    No. 21-14005 (11th Cir. Sep. 20, 2022)   Cited 3 times

    The test does not apply where the evidence is "pointedly dissimilar" from the event at issue and "not offered to reenact the accident." Tran v. Toyota Motor Corp., 420 F.3d 1310, 1316 (11th Cir. 2005) (quotation omitted).

  7. Tambourine Comercio v. Solowsky

    312 F. App'x 263 (11th Cir. 2009)   Cited 43 times
    Holding that a district court correctly applied section 95.11 to a claim for breach of fiduciary duty involving an attorney-client relationship

    Inherent in this standard "is the firm recognition that there are difficult evidentiary rulings that turn on matters uniquely within the purview of the district court, which has first-hand access to documentary evidence and is physically proximate to testifying witnesses and the jury." Tran v. Toyota Motor Corp., 420 F.3d 1310, 1315 (11th Cir. 2005) (quotation and citation omitted).III.

  8. Crouch v. Teledyne Continental Motors, Inc.

    Civil Action No. 10-00072-KD-N (S.D. Ala. Jul. 6, 2011)

    "[I]n the Eleventh Circuit, the admission of other incidents is generally governed by the federal substantial similarity doctrine, not state law." Colp v. Ford Motor Co., 279 Ga.App. 280, 630 S.E.2d 886, 890 (2006) (citing Tran v. Toyota Motor Corp., 420 F.3d 1310, 1316 (11th Cir. 2005) and Heath v. Suzuki Motor Corp., 126 F.3d 1391, 1395-96 (11th Cir. 1997)); Heath, 126 F.3d at 1396 ("Under this circuit's controlling precedent regarding diversity jurisdiction cases, the admissibility of evidence is a procedural issue, and therefore is governed by the Federal Rules of Evidence."). In Tran, the Court of Appeals for the Eleventh Circuit explained the "substantial similarity doctrine" as follows:

  9. Bratt v. Genovese

    No. 18-14849 (11th Cir. Aug. 9, 2019)   Cited 5 times

    When the district court abuses its discretion, "an erroneous evidentiary ruling is a basis for reversal only if the complaining party's substantial rights were affected." Proctor v. Fluor Enters., Inc., 494 F.3d 1337, 1352 (11th Cir. 2007) (citing Tran v. Toyota Motor Corp., 420 F.3d 1310, 1316 (11th Cir. 2005)). The party asserting error bears the burden of proving his substantial rights were affected.

  10. Moore v. Geico Gen. Ins. Co.

    No. 17-13655 (11th Cir. Dec. 14, 2018)   Cited 8 times   1 Legal Analyses
    Concluding the district court did not abuse its discretion in determining that the probative value of allowing evidence of another insurer's claim handling was outweighed by the danger of unfair prejudice and of confusing the issues and misleading the jury under Rule 403

    "Inherent in this abuse of discretion standard is the firm recognition that there are difficult evidentiary rulings that turn on matters uniquely within the purview of the district court, which has first-hand access to documentary evidence and is physically proximate to testifying witnesses and the jury." Tran v. Toyota Motor Corp., 420 F.3d 1310, 1315 (11th Cir. 2005) (internal quotation marks, alteration omitted). Evidence of claimants' settlement with Peak certainly had some probative value.