Suzuki Motor Corporation v. Scott Winckler
Scott Winckler suffered permanent paralysis when the front brakes of a 2007 Suzuki GSX-R1000 motorcycle failed, allegedly due to a known defect in the front brake master cylinder. After four trials and a decade of litigation, a jury found Suzuki liable for negligent failure to warn, and the trial court entered final judgment. The Fifth DCA affirmed on both grounds raised by Suzuki: (1) a prior defense verdict on the strict liability design-defect claim did not preclude the separate negligent warning claim; and (2) evidence of Suzuki's safety recall was properly admitted.
Key facts
- Scott Winckler was riding a 2007 Suzuki GSX-R1000 motorcycle belonging to his friend Paul Barker when the front brakes failed at an intersection, causing a collision with an SUV; Winckler was thrown from the motorcycle and suffered permanent paralysis from the waist down.
- Suzuki had issued a safety recall in October 2013 covering Barker's motorcycle because corrosion of the brake piston inside the front brake master cylinder could reduce fluid pressure transmission to the front brake; Winckler sued Suzuki in June 2014 asserting both strict liability design defect and negligent warning defect.
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Holdings
- A defense verdict on a strict liability design-defect claim does not necessarily preclude a separate negligent warning claim; even a product that leaves the manufacturer without a design…
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Why it matters
This case clarifies that strict liability and negligent warning are independent theories in Florida products liability litigation. Defense practitioners must object to inconsistent verdict forms before the jury is… — full analysis with a trial
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