Wilson v. Vermont Castings

Vermont Castings (defendant) made wood stoves. Ann Wilson (plaintiff) was injured when her clothes ignited while starting a fire in her stove, and she and Oliver Larmi (plaintiff) sued on strict-liability and negligence theories; only strict liability went to trial. The court excluded the stove's instruction manual as irrelevant, since there was no indication Wilson had seen it. The jury was asked whether the stove was defective and whether the defect proximately caused the injury; it found the stove defective but that the defect did not cause the injury. After trial, the plaintiffs learned one juror owned a Vermont stove, had read its manual during deliberations, and told the other jurors about its warnings and that she kept her stove door ajar. The plaintiffs moved for a new trial for juror misconduct.

Whether, under the Federal Rules of Evidence, a jury verdict must be overturned when a juror was exposed to extraneous information during deliberations.