1. Juror 5
The action is in California Superior Court, so California’s rules governing challenges for cause matter. Actual bias concerns the juror’s state of mind. Implied bias concerns specified relationships and interests for which the statute supplies a disqualification ground even if the juror believes she can be fair.
Code of Civil Procedure section 229(b) expressly includes holding shares in a corporate party. Juror 5 directly owns fifty Motor shares. The fact that they represent only two percent of her assets does not create a stated de minimis exception to this stockholder ground. Her assurance of impartiality therefore does not answer the implied-bias challenge. On that basis, seating her over the challenge was error.
Her former engineering job is a separate concern. Employment ending five years ago does not by itself establish a present employer–employee relationship, and no facts show that she designed this seat or has personal knowledge of the accident. It may warrant further inquiry into actual bias, but the existing stock ownership supplies the stronger statutory ground. Neither an assumption that she designed the product nor a finding that she intentionally concealed her holdings is needed.
2. Directed verdict
A directed verdict is proper when, giving the opposing party the benefit of the evidence and reasonable inferences, no sufficient evidentiary basis supports a verdict in its favor. The judge does not resolve genuine credibility disputes as though deciding the ultimate facts.
Palma argues that foreseeable misuse does not categorically defeat a design-defect claim. That is a meaningful legal proposition: manufacturers must account for reasonably foreseeable use and misuse, while comparative responsibility and extraordinary misuse can present distinct questions. But it does not eliminate Palma’s obligation to establish a defect and causation.
Motor presented evidence that the seat was not defective and that excessive reclining caused the injury. Palma’s bookshelf evidence contradicts that factual account, but a contradiction ordinarily gives the jury an issue to resolve. Accepting her evidence and rejecting Motor’s would improperly weigh the dispute on this motion. A reasonable jury could credit Motor’s evidence concerning design or causation. Denial of directed verdict was therefore proper on the record then available.
The later-discovered test reports cannot retroactively be treated as evidence before the court at the close of trial. They matter to post-trial relief, not to whether the judge correctly evaluated the evidentiary record at that earlier moment.
3. New-trial motion
Grounds and supporting proof
Section 657 allows a new trial for specified errors materially affecting substantial rights, including qualifying newly discovered evidence and irregularity preventing a fair trial. Palma must establish that the reports are genuine and material, that reasonable diligence would not have produced them at trial, and the requisite likelihood of a different result. An anonymous source does not automatically make the underlying corporate test records unusable, but it makes authentication and supporting declarations important.
The reports predate trial, address the precise safety question, and indicate severe injuries regardless of seat angle. They could undermine Motor’s main factual explanation. Evidence that Motor deliberately concealed them supports the inability to obtain them through reasonable diligence and a separate unfair-trial argument. It is stronger than merely discovering a different expert opinion after losing. If adequately established, these facts strongly support a new trial; they do not automatically direct entry of judgment for Palma or eliminate every remaining defect and causation issue.
Timing
California section 659 is not a general twenty-eight-day federal deadline. The ordinary outer limit is 180 days after entry of judgment, shortened to fifteen days after the applicable clerk or party service of notice of entry, whichever occurs first. A qualifying notice of intention to move is required, and discovering evidence does not ordinarily restart that period.
Palma filed approximately twenty-one days after judgment. If notice of entry was served at judgment, a first notice filed then is late. If no shortening notice was served, the filing falls within the outer limit. The problem does not state service of notice or an earlier notice of intention, so timeliness must be conditional rather than invented. Assuming timely compliance, the concealed material evidence supports granting a new trial. If the jurisdictional filing period expired, strong merits alone do not extend it.