Chrysler Corporation, a Delaware Corporation, Appellant (defendant Below), Floyd A. Rummell, Iii (defendant Below)…

Summary

This opinion resolves an appeal from a $400,000 judgment (reduced from a $450,000 verdict) against Chrysler for injuries enhanced when the plaintiff sheriff's seat bracket failed in a rear-end collision. The court adopted the 'second collision' rule charging automobile manufacturers with foreseeing collisions in design, but held that because the injuries were indivisible, liability was joint and several and the parties' relative responsibilities had to be resolved under Wyoming's contribution statutes rather than by apportioning enhanced-injury damages. Reversal and a new trial were nonetheless required because the trial court prejudicially restricted Chrysler's cross-examination of the plaintiff's expert concerning federal seat standards and admitted speculative opinion testimony that the plaintiff lost his bid for reelection as sheriff because of his injuries. The court sustained the ruling that the plaintiff was not negligent as a matter of law and directed that, on remand, Chrysler be allowed to pursue its cross-claim against the settling driver, with the trial court first determining any disproportion of fault before submitting relative fault to the jury.