Billion-Dollar Verdict Overturned: Trial Court's Refusal Of Non-Standard Jury Instruction Proves Fatal

On Dec. 22, 2025, a three-judge panel of the Superior Court of Pennsylvania, in a non-precedential opinion, vacated a highly publicized $1 billion jury verdict against Mitsubishi from 2023. The Superior Court not only vacated the verdict but also remanded the case for a new trial. This ruling underscores a lesson for litigators: the trial court's refusal to incorporate a non-standard jury instruction on the crashworthiness doctrine—despite its applicability to the case—proved to be a reversible error that invalidated one of the largest verdicts ever handed out in Philadelphia County.

The case, Amagasu v. Fred Beans Family of Dealershipset al., arose following a motor vehicle accident on Nov. 11, 2017, that rendered Francis Amagasu a quadriplegic. Mr. Amagasu was driving a 1992 Mitsubishi 3000GT in Bucks County, Pa. when he attempted to pass another car and lost control of his vehicle. The car veered off the road, hit several trees, and rolled over. As the car rolled over, Mr. Amagasu's head struck the vehicle's roof, which compressed his cervical spine and left him paralyzed from the neck down.

The Amagasus contended that the Mitsubishi 3000GT was defectively designed. Specifically, they argued the car's seat belt system, which contained a "rip-stitch," designed to rip during a collision, added approximately four inches of slack when ripped. This extra slack, combined with the lack of head clearance (about three inches) in the vehicle, rendered it unreasonably dangerous to consumers in the event of a crash.

Crashworthiness Doctrine: Critical Legal Standard in Product Liability Cases

Prior to the trial, which commenced in October 2023, the parties disputed whether the trial court was required to instruct the jury on the "crashworthiness doctrine." The crashworthiness doctrine applies in situations where the defect in question did not cause the accident but is alleged to have increased the severity of plaintiff's injuries. Mitsubishi asked the trial court to instruct the jury on the crashworthiness doctrine, while plaintiffs asked the trial court to instruct the jury in accordance with the Pennsylvania Suggested Standard Civil Jury Instructions for general strict liability.

The trial court sided with the Amagasus and declined to instruct the jury on the crashworthiness doctrine. Later that month, the jury returned a verdict in the Amagasus' favor, awarding $156 million in compensatory damages, $20 million to Mrs. Amagasu, specifically, for loss of consortium, and another $800 million in punitive damages. Following the trial, Mitsubishi filed a post-trial motion seeking judgment notwithstanding the verdict, a new trial, and remittitur. The trial court denied Mitsubishi's motion and, in turn, granted the Amagasus' motion for delay of damages and entered the final judgment, totaling just over $1 billion.

Subsequently, in May 2024, Mitsubishi appealed the judgment, challenging the trial court's ruling on multiple fronts, including the sufficiency of the evidence regarding plaintiff's design and warning-defect claims and the punitive damages awarded. However, the Superior Court only addressed the first issue Mitsubishi raised: whether a new trial is required because the trial court erred by failing to instruct on crashworthiness. The Court concluded that a new trial is required.

Superior Court Analysis: Why Crashworthiness Instructions Were Required

The core issue stems from the fact that the crashworthiness doctrine imposes a more demanding standard of proof than a traditional product liability claim. Under the crashworthiness doctrine, plaintiffs must prove the existence of an alternative, safer design and show how the alleged defect contributed to their injuries beyond those that were unavoidable, elements which are not ordinarily required in a traditional product liability action.

In its opinion, the Superior Court explained that the Amagasus had, in fact, pursued a crashworthiness case from the beginning because their complaint never alleged that the design defect, i.e., the seatbelt system and roof configuration, caused the accident. Instead, they stated the design of the seatbelt system caused Mr. Amagasu to sustain enhanced injuries during the rollover sequence, which occurred after he already lost control of the vehicle.

The Superior Court likened the present case to Colville, where the plaintiff's foot was injured in a forklift accident. 809 A.2d 916 (Pa. Super. 2002). There, Mr. Colville pursued a strict product liability action against the forklift's manufacturer and seller. The complaint alleged the forklift was defective because it was designed and manufactured without a door enclosing the operator's compartment. The defendants asked the trial court to issue jury instructions on the crashworthiness doctrine, but the court denied defendants request and the jury returned a verdict in Coleville's favor. On appeal, the Superior Court held that the trial court should have issued a jury instruction explaining the elements of the crashworthiness doctrine because the absence of a door only enhanced the severity of plaintiff's injury, it did not cause him to crash the forklift.

In conclusion, the Superior Court chastised the trial court for denying Mitsubishi's request for a jury instruction on the crashworthiness doctrine, calling it "not a logical and dispassionate determination based on review of pertinent case law or evidence presented at trial." The Court also emphasized that just because the crashworthiness doctrine is not included in the Pennsylvania Suggested Standard Civil Jury Instructions, does not mean that the trial court can cast aside the doctrine. Rather, the Court stated that the Pennsylvania Suggested Standard Civil Jury Instructions are not meant to be "conclusive, but merely a guide." Lastly, it called the trial court's policy of mandating that parties agree before issuing a non-standard jury instruction "manifestly unreasonable."

Legal Implications: Potential Impact on Jury Instructions and Future Verdicts

Overall, Amagasu v. Fred Beans Family of Dealershipset al. suggests that trial courts should not be overly reliant on form jury instructions and counsel may wish to advocate for the use of non-standard jury instructions when applicable. Further, this case signals the Superior Court's growing scrutiny of giant jury verdicts and its willingness to rein in excessive jury awards when they contravene established legal standards.

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