Precedents Cited

The Court extensively referenced several key precedents to bolster its decision:

• KENNEDY v. DIXON, 439 S.W.2d 173 (Mo. banc 1969) - Established the application of Restatement (Second) of Conflict of Laws §145 for determining the substantive law in tort cases.
• KEENER v. DAYTON ELECTRIC MANUFACTURING COmpany, 445 S.W.2d 362 (Mo. 1969) - Adopted Restatement (Second) of Torts §402A, defining strict liability in products liability.
• BLEVINS v. CUSHMAN MOTORS, 551 S.W.2d 602 (Mo. banc 1977) - Extended strict liability to product design defects, aligning it with manufacturing defects.
• CRYTS v. FORD MOTOR CO., 571 S.W.2d 683 (Mo.App. 1978) - Clarified that state of the art evidence is irrelevant in strict liability claims focused on defective conditions.
• BAUMLE v. SMITH, 420 S.W.2d 341 (Mo. 1967) - Addressed the competence to impeach jury verdicts.

These precedents collectively influenced the Court's stance on the applicability of Missouri law, the irrelevance of the state of the art defense in strict liability contexts, and the proper handling of jury verdicts.

Legal Reasoning

The Court's legal reasoning centered on several pivotal points:

• Statute of Limitations: The Court applied Missouri's five-year statute of limitations, arguing that the cause of action accrued when Mr. Elmore was diagnosed with asbestosis in Missouri, not Kansas. This decision was supported by Restatement §145, emphasizing that the place where the injury is sustained and where the parties have significant relationships determines the applicable law.
• State of the Art Defense: Owens-Illinois attempted to invoke a state of the art defense, claiming they could not have known about the dangers of asbestos during the time Kaylo was manufactured. The Court held that under strict liability, the focus is on the product's defective condition rather than the manufacturer's knowledge or negligence. Therefore, the state of the art defense was deemed irrelevant in this context.
• Jury Verdict Modification: The trial court's reduction of the jury's verdict was scrutinized. The Court found that the trial court improperly intervened based solely on juror affidavits without any record evidence indicating ambiguity or error in the jury's calculations, violating precedents like BAUMLE v. SMITH. As a result, the original verdicts were reinstated.

Impact

This judgment has far-reaching implications for products liability law in Missouri:

• Strict Liability Clarification: By affirming that the state of the art defense is not applicable in strict liability cases focusing on product defects, the Court reinforces the principle that manufacturers are held accountable based on the product's inherent dangers, irrespective of their knowledge at the time of manufacture.
• Statute of Limitations Enforcement: The decision emphasizes the application of the statute of limitations based on where the injury accrues, affecting how future cases involving multiple jurisdictions may be approached.
• Jury Verdict Integrity: Reinforcing the sanctity of jury verdicts unless there is clear evidence of error ensures that jurors' decisions are respected, limiting judicial interference in the absence of procedural or factual ambiguities.

Consequently, manufacturers operating in Missouri must exercise heightened diligence regarding product safety, as the avenues for defense based on lack of knowledge or state of the art advancements are constrained.