Norton v. Snapper Power Equipment

806 F.2d 1545 (11th Cir. 1987)


Plaintiff bought a riding mower from defendant company.  While using the mower to clear leaves from a yard, plaintiff reached the top of an incline and the mower then began to slide backwards toward a creek.  Plaintiff testified that he applied the brakes but the mower continued to slide and crashed into the creek, at which point he was knocked off the seat and his hands somehow got caught in the blades, amputating four of his fingers.

Procedural History

A jury returned a verdict for plaintiff on his strict liability claim, after which the district court entered a judgment notwithstanding the verdict in favor of defendant, holding that there was not sufficient evidence for a jury to find that there was an inherent defect in the product at the time it was purchased and that it caused plaintiff’s injury, as required by law to hold defendant strictly liable.


Did the district court err in granting a judgment notwithstanding the verdict to defendant on plaintiff’s strict liability claim?

Holding / Rule

Yes.  Reversed.  In deciding whether to grant a judgment notwithstanding the verdict, the court must consider the evidence in the light most favorable to the non-moving party and should grant the judgment only where the evidence so strongly and so favorably points in the favor of the moving party that reasonable people could not arrive at a contrary verdict.


The jury could reasonably have found that the mower was defective because of defendant’s failure to install a “dead man” device that could stop the blades from spinning in less than one second after the operator applies the brakes or releases the handle.  Moreover, while plaintiff was not sure how his hands got caught in the blades, the jury was permitted to reconstruct the series of events by drawing inferences based on the available evidence.  The blades on the mower would have continued to spin for three to five seconds after plaintiff released the handle when the mower hit the creek, and experts testified that a two or three second difference in blade stopping time would have avoided the injury.

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