Bruther v. General Electric Co.
United States District Court for the Southern District of Indiana
818 F. Supp. 1238 (S.D. Ind. 1993)
Bruther (plaintiff) was electrocuted when a light bulb he was replacing shattered at work, and later sued the bulb's alleged manufacturer, GE (defendant), for products liability. The bulb wasn't secured immediately after the injury; another employee later found a broken bulb in a nearby cabinet and believed it was the one in question because the workplace wouldn't normally keep a broken bulb around, and only six employees had access to that area. Bruther also submitted an affidavit that he had recently installed other GE bulbs at the same workplace; GE moved for summary judgment, challenging the bulb's authentication.
Whether a proffered item of physical evidence satisfies the authentication requirement of Federal Rule of Evidence 901 where circumstantial evidence supports a finding that the item is what its proponent claims it to be.