Robert C. Sinclair, Jr., as Administrator of the Estate of Pamela Marie Sinclair vs. Stans Harley Davidson, Inc. et al

Case Background

The plaintiff, Robert C. Sinclair Jr., filed the lawsuit on June 2, 2022, in the New York State Supreme Court, Livingston County (Case number: 000403-2022). Judge Craig J. Doran presided over the case.

Cause

On August 23, 2020, Pamela Marie Sinclair, a 55-year-old resident of LeRoy, New York, rode her 2018 Harley-Davidson Street Rod motorcycle. She traveled northbound on State Route 19 in Warsaw, Wyoming County, New York. As Pamela approached the intersection with Route 20A, her motorcycle suddenly lost power and stalled. Despite her efforts, she could not restart the motorcycle or move it off the roadway. While stranded in the travel lane, another vehicle struck her from behind. The violent collision ejected Pamela from the motorcycle, causing catastrophic injuries. Emergency responders rushed her to a nearby hospital, where she fought for her life for two days before succumbing to her injuries on August 25, 2020. Investigators revealed that a malfunction in the motorcycle's engine control module (ECM), manufactured by Robert Bosch LLC, caused the sudden power loss. The malfunction left Pamela vulnerable on the road. She had purchased the motorcycle from Stan's Harley-Davidson, Inc., a local dealership in Batavia, New York. Harley-Davidson Motor Company Group, LLC was responsible for the motorcycle's overall design and manufacture.

Injuries

The collision caused Pamela Marie Sinclair devastating injuries, including severe head trauma, likely resulting in traumatic brain injury. She also sustained multiple internal injuries, potentially involving damage to vital organs. The impact fractured numerous parts of her body, including possible spinal, rib, and limb fractures. In her final days, Pamela endured extreme physical pain and emotional distress, experiencing fear and anxiety about her condition and prognosis. Her injuries proved too severe to overcome, leading to her death on August 25, 2020, just two days after the accident.

Damages

As the administrator of Pamela's estate, Robert C. Sinclair Jr. sought comprehensive damages to address the profound loss suffered by Pamela and her family. The wrongful death claim aimed to compensate for the loss of Pamela's future earnings, benefits, and financial contributions to her family. It also sought to address the intangible loss of her love, companionship, guidance, and support. The claim for pain and suffering focused on the physical and emotional trauma Pamela experienced between the accident and her death. The plaintiff also sought damages for medical expenses incurred during Pamela's final hospitalization, as well as funeral and burial costs. The loss of services claim addressed the value of Pamela's contributions to her household and family life. Additionally, the plaintiff sought punitive damages, arguing that the defendants' conduct was particularly egregious and warranted additional punishment to deter similar behavior in the future. The total damages sought exceeded the jurisdictional limits of lower courts, reflecting the significant financial impact of this tragedy.

Key Arguments and Proceedings

Legal representation

• Plaintiff(s): Robert C. Sinclair, Jr., as Administrator of the Estate of Pamela Marie Sinclair
  • Counsel for Plaintiff: Daniel Thomas| Paul Edelstein

• Defendant(s):Stans Harley Davidson, Inc. | Harley Davidson Motor Company Group, LLC | Robert Bosch LLC
  • Counsel for Defendants: Thomas Lane | Anthony J. Monaco | Kristen A Cooke | Sarah Scullen | Mark Kircher | Steven R. Hamlin | Michael Christopher Pretsch

Claims

The lawsuit alleged multiple claims against the defendants: Negligence: The complaint asserted that all defendants—Stan's Harley-Davidson, Inc., Harley-Davidson Motor Company Group, LLC, and Robert Bosch LLC—failed in their duty of care. They allegedly did not properly design, manufacture, test, or inspect the motorcycle and its critical components, particularly the engine control module. The plaintiff argued that reasonable care in these processes would have prevented the fatal malfunction. Strict Products Liability: This claim focused on inherent defects in the motorcycle and engine control module, regardless of the level of care exercised by the defendants. The plaintiff alleged that the motorcycle was unreasonably dangerous due to defects in its design and manufacture, making it unsafe for its intended use. Breach of Warranty: The lawsuit claimed that the defendants breached both express and implied warranties. Express warranties included specific promises about the motorcycle's performance and reliability. Implied warranties of merchantability and fitness for a particular purpose were also allegedly breached, as the motorcycle was not suitable for its ordinary purpose of safe transportation. Failure to Warn: The complaint alleged that the defendants failed to provide adequate warnings about potential defects and hazards associated with the motorcycle and its components. This included a lack of proper instructions for safe operation and maintenance, as well as failure to communicate known risks. Negligent Misrepresentation: The plaintiff claimed that the defendants made false or misleading statements about the motorcycle's safety, reliability, and performance. These misrepresentations allegedly led Pamela to purchase and operate the motorcycle, directly contributing to the accident. The lawsuit also addressed potential defenses, asserting that the case fell under exceptions to limitations on liability under New York law. This aimed to ensure that the defendants could be held fully accountable for their alleged role in Pamela's death.

Defense

Stan's Harley-Davidson, Inc. responded to the lawsuit by denying knowledge or information sufficient to form a belief about most of the allegations in the complaint. The defendant specifically denied any wrongdoing or liability for the accident and Pamela Sinclair's death. The defendant asserted several affirmative defenses. They claimed that the plaintiff's damages, if any, resulted from Pamela Sinclair's own negligence or actions by other parties over which the defendant had no control. Stan's argued that any recovery should be reduced in proportion to Pamela's comparative negligence. The answer also raised the defense that the complaint failed to state a cause of action against Stan's Harley-Davidson. The defendant contended that if any defect existed in the motorcycle, it was latent and not discoverable by reasonable inspection. They claimed they lacked privity with Pamela Sinclair and that any warranties were disclaimed or limited. Stan's Harley-Davidson further asserted that Pamela Sinclair assumed the risk of using the motorcycle and that her injuries resulted from misuse or alteration of the product. They argued that the alleged defect did not exist when the product left their control. The defendant also raised defenses based on the statute of limitations, failure to mitigate damages, and intervening superseding causes.

Jury Verdict

On August 13, 2024, the jury awarded a total of $287 million in damages. This included $120 million in punitive damages to Morris and $120 million to Pamela Marie Sinclair's estate, totaling $240 million. The jury also awarded $47 million for pain and suffering. Court Documents: Available Upon Request