Wilson v. Vermont Castings, Inc.

Anne Wilson (plaintiff) owned a Vermont Castings (defendant) wood stove and was severely injured when her dress caught fire while she used the stove with a side door open. She sued for defective design. Because Wilson had never read the stove's owner manual, the trial court excluded it. During deliberations, a juror who owned the same stove told other jurors about her experience, including that she often left the side door open and would not change that behavior even with a warning. The jury found the stove defective but that the defect was not a substantial factor in causing the injury. Wilson's lawyer later learned of these deliberations and moved for a new trial, arguing the juror improperly discussed her own manual and her stove-use habits. The district court denied the motion, and Wilson appealed.

Whether a court may inquire into a jury's verdict where no extraneous prejudicial information was brought to the jury's attention and no improper outside influence was exerted.