Benavides v. Tesla, Inc

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 21-cv-21940-BLOOM/Torres
NEIMA BENAVIDES, as Personal
Representative of the Estate of Naibel
Benavides Leon, deceased, and
DILLON ANGULO,
Plaintiffs,
v.
TESLA, INC., a/k/a.
TESLA FLORIDA, INC.,
Defendant.
_________________________________/
ORDER ON AMENDED RENEWED MOTION FOR JUDGMENT AS A MATTER OF
LAW OR, ALTERNATIVELY, MOTION FOR NEW TRIAL
THIS CAUSE is before the Court upon Defendant Tesla Inc’s (“Tesla”) Amended
Renewed Motion for Judgment as a Matter of Law or, Alternatively, Motion for a New Trial or to
Amend the Judgment (“Motion”). ECF No. [591]. Plaintiffs Neima Benavides, as personal
representative of the Estate of Naibel Benavides Leon, and Dillon 	Angulo (collectively
“Plaintiffs”) filed a Response, ECF No. [602], to which Tesla filed a Reply, ECF No. [603]. The
Court has carefully reviewed the Motion, the supporting and opposing submissions, the record in
this case, the applicable law, and is otherwise fully advised. For the reasons that follow, the Motion
is denied.
I. 	BACKGROUND
This matter arises from a collision that occurred in Key Largo, Florida. George McGee
owned a 2019 Tesla Model S (“Vehicle”) “equipped with automatic driving features, one of which
Tesla termed ‘Autopilot,’ that could navigate without driver input.” ECF No. [205] at 3. On April
Case 1:21-cv-21940-BB Document 612 Entered on FLSD Docket 02/20/2026 Page 1 of 8

Case No. 21-cv-21940-BLOOM/Torres
2
25, 2019, McGee was driving the Vehicle when it hit a parked Chevrolet Tahoe, which then struck
Decedent Naibel Benavides Leon and Plaintiff Dillon Angulo, killing Benavides Leon and causing
significant injuries to Angulo. See id. at 3-4.
While 	Plaintiffs 	originally 	filed 	separate 	actions 	against 	Tesla, 	their 	cases 	were
consolidated, and on March 11, 2024, Plaintiffs filed an Amended Complaint asserting the
following claims against Tesla: Strict-Products-Liability—Defective design (Count I), Failure to
Warn (Count II), Defective Manufacture (Count III), and Negligent Misrepresentation (Count IV).
ECF No. [205]. On June 26, 2025, the Court issued an Omnibus Order on Motion for Summary
Judgment, ECF No. [428], wherein the Court dismissed Counts III and IV but allowed Count I
(the Defective Design), Count II (Failure to Warn), and the demand for punitive damages to
proceed to trial.
When the case ultimately advanced to trial, the jury found in favor of Plaintiffs on both
Counts I and II and found Tesla liable for punitive damages. ECF No. [534]. On August 3, 2025,
the Court entered a Final Judgment against Tesla in the amount of $242,570,000.00. ECF No.
[538]. The $242,570,000.00 award consisted of $19,470,000.00 in compensatory damages
awarded to the Estate of Naibel Benavides, $23,100,000.00 in compensatory damages awarded to
Dillon Angulo, and $200,000,000.00 in punitive damages to be split between the Plaintiffs.
Tesla now seeks a judgment as a matter of law or, alternatively, a new trial. ECF No. [591].1
Tesla argues that a judgment as a matter of law is appropriate as to the issue of liability because
(1) the verdict is unsupported by reliable expert evidence, (2) the record evidence does not support
Plaintiffs’ Defective Design claim, as Tesla’s 2019 Model S was not proven to be defective or the
1 While the Jury Verdict states that the jury awarded the Estate of Naibel Benavides Leon $59,000,000.00
and Dillon Angulo $70,000,000.00 in compensatory damages, the jury found Tesla to be only 33%
responsible for Plaintiffs’ injuries. See ECF No. [534]. As such, the compensatory award for each Plaintiff
was reduced accordingly in the Final Judgment to reflect the jury’s findings.
Case 1:21-cv-21940-BB Document 612 Entered on FLSD Docket 02/20/2026 Page 2 of 8

Case No. 21-cv-21940-BLOOM/Torres
3
cause Plaintiffs’ injuries, and (3) the record evidence does not support Plaintiffs’ Failure to Warn
claim because (i) Tesla had no duty to warn, (ii) Tesla provided extensive warnings, (iii) and the
purported failure to warn did not cause the subject crash. See generally ECF No. [591]. Tesla
further maintains that judgment as a matter of law on the issue of punitive damages is necessary,
or at least a significantly reduced punitive damages award should be granted, because (1) Florida
law prohibits the imposition of punitive damages in this type of case, (2) Florida law caps punitive
damages at three times compensatory damages actually awarded, and (3) the Due Process Clause
limits punitive damages to no more than the net award of compensatory damages.2 Id.
Alternatively, Tesla contends that the lack of evidence to support the verdict warrants a
new trial. Id. Tesla further argues that a new trial is needed based on several highly prejudicial
evidentiary errors, including (1) the improper admission of data-related evidence obtained from
the Vehicle, (2) the improper admission of statements made by Elon Musk, and (3) the improper
admission of certain other dissimilar accidents. Id.
Plaintiffs respond that a judgment as a matter of law or a new trial on liability is not
warranted. See generally ECF No. [602]. Plaintiffs argue that the Court already found their experts’
opinions to be reliable on summary judgment, and Plaintiffs offered substantial competent
evidence at trial establishing that there were defective designs in the Vehicle’s Autopilot that
partially caused the subject crash. Id. Plaintiffs maintain they also provided sufficient evidence to
support their Failure to Warn claim, as there was evidence that the warnings in the Vehicle were
inadequate, and the inadequacy of the warnings contributed to the subject crash. Id.
Regarding punitive damages, Plaintiffs contend that the $200,000,000.00 award should not
be disturbed. According to Plaintiffs, punitive damages are available in automotive defect cases
2 Tesla also argues that the Court should reduce Plaintiffs’ compensatory award to no more than $69 million.
Case 1:21-cv-21940-BB Document 612 Entered on FLSD Docket 02/20/2026 Page 3 of 8

Case No. 21-cv-21940-BLOOM/Torres
4
and are appropriate in this case because Tesla was grossly negligent in its development of
Autopilot and its response to previous Autopilot failures. Id. Plaintiffs argue the punitive damage
award comports with due process, as Tesla’s conduct was shown to be reprehensible, the ratio of
compensatory and punitive damages (1.4 to 1) was not unreasonable, and comparable cases should
have placed Tesla on notice of the potential for a large punitive award. Id.
Regarding Tesla’s request for a new trial, Plaintiffs contend that the Autopilot data from
the Vehicle, Elon Musk’s statements, and the evidence of similar accidents were properly admitted
at trial and, therefore, there is no substantial error that would justify a new trial. As the Motion is
fully briefed, it is ripe for review.
II. 	LEGAL STANDARD
A. Rule 50—Motion for Judgment as a Matter of Law
Federal Rule of Civil Procedure 50 “governs motions for judgment as a matter of law in
jury trials [and] allows the trial court to remove cases or issues from the jury’s consideration ‘when
the facts are sufficiently clear that the law requires a particular result.”’ Weisgram v. Marley Co.,
528 U.S. 440, 447-48 (2000) (quoting 9A C. Wright & A. Miller, Federal Practice and Procedure
§ 2521, p. 240 (2d ed. 1995)).
Under Rule 50, “judgment as a matter of law is appropriate only if the facts and inferences
point so overwhelmingly in favor of one party . . . that reasonable people could not arrive at a
contrary verdict.” Brown v. Ala. Dep’t of Transp., 597 F.3d 1160, 1173 (11th Cir. 2010) (quotation
marks omitted; alteration in the original). The Court must consider the evidence in the light most
favorable to the nonmoving party and determine “whether or not reasonable jurors could have
concluded as this jury did based on the evidence presented.” Combs v. Plantation Patterns, 106
F.3d 1519, 1526 (11th Cir. 1997) (citation omitted). It is “the jury’s task,” not the Court’s, “to
weigh conflicted evidence and inferences, and determine the credibility of witnesses.” McGinnis
Case 1:21-cv-21940-BB Document 612 Entered on FLSD Docket 02/20/2026 Page 4 of 8

Case No. 21-cv-21940-BLOOM/Torres
5
v. Am. Home Mortg. Servicing, Inc., 817 F.3d 1241, 1254 (11th Cir. 2016) (quotation marks and
citation omitted); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986) (“Credibility
determinations, the weighing of the evidence, and the drawing of legitimate inferences from the
facts are jury functions, not those of a judge, whether he is ruling on a motion for summary
judgment or for a directed verdict.”).
Insofar as the evidence is considered when reviewing a motion for judgment as a matter of
law, the Supreme Court has stated:
[A]lthough the court should review the record as a whole, it must disregard all
evidence favorable to the moving party that the jury is not required to believe. That
is, the court should give credence to the evidence favoring the nonmovant as well
as 	that 	evidence 	supporting 	the 	moving 	party 	that 	is 	uncontradicted 	and
unimpeached, at least to the extent that that evidence comes from disinterested
witnesses.
Reeves v. Sanderson Plumbing Prods. Inc., 530 U.S. 133, 151 (2000) (internal quotations omitted)
(citations omitted), quoted in Cadle v. GEICO Gen. Ins. Co., 838 F.3d 1113, 1127 (11th Cir. 2016).
If the court does not grant a Rule 50(a) motion, the movant may file “a renewed motion,”
under Fed. R. Civ. P. 50(b). A Rule 50(b) motion is made after the case has been submitted to the
jury, “thereby insuring that a motion for such a judgment is used only to invite the district court to
reexamine its decision not to direct a verdict as a matter of law, not to reexamine facts found by
the jury.” 27A Fed. Proc., L. Ed. § 62:695 (Supp. 2022) (emphasis added). “[A]ny renewal of a
motion for judgment as a matter of law under Rule 50(b) must be based upon the same grounds as
the original request for judgment as a matter of law made under Rule 50(a) at the close of the
evidence and prior to the case being submitted to the jury.” Doe v. Celebrity Cruises, Inc., 394
F.3d 891, 903 (11th Cir. 2004).
“The standard for granting a renewed motion for judgment as a matter of law under
Rule 50(b) is precisely the same as the standard for granting the pre-submission
motion [under 50(a)].” Chaney v. City of Orlando, 483 F.3d 1221, 1227 (11th Cir.
Case 1:21-cv-21940-BB Document 612 Entered on FLSD Docket 02/20/2026 Page 5 of 8

Case No. 21-cv-21940-BLOOM/Torres
6
2007) (alteration in original) (quoting 9A Charles Alan Wright & Arthur R. Miller,
Federal Practice and Procedure § 2537 (2d ed. 1995)). Thus, as with motions
under Rule 50(a), the question before a district court confronting a renewed Rule
50(b) motion is whether the evidence is “legally sufficient . . . to find for the party
on that issue.” Fed. R. Civ. P. 50(a)(1).
McGinnis v. Am. Home Mortg. Servicing, Inc., 817 F.3d 1241, 1254 (11th Cir. 2016); see also
Chaney v. City of Orlando, Fla., 483 F.3d 1221, 1127 (11th Cir. 2007) (“Regardless of timing, [ ]
in deciding on a Rule 50 motion a district court’s proper analysis is squarely and narrowly focused
on the sufficiency of evidence. The question before the district court regarding a motion for
judgment as a matter of law remains whether the evidence is “legally sufficient to find for the party
on that issue,” [ ] regardless of whether the district court’s analysis is undertaken before or after
submitting the case to the jury.”).
B. Motion for a New Trial
Pursuant to Federal Rule of Civil Procedure 59(a)(1), “[t]he court may, on motion, grant a
new trial . . . after a jury trial, for any reason for which a new trial has heretofore been granted in
an action at law in federal court.” Fed. R. Civ. P. 59(a)(1)(A). A motion for new trial may be
brought on the basis that “the verdict is against the weight of the evidence, that damages are
excessive, or that, for other reasons, the trial was not fair to the [moving party]; and [a motion for
new trial] may raise questions of law arising out of alleged substantial errors in admission or
rejection of evidence or instructions to the jury.” Alphamed Pharm. Corp. v. Arriva Pharms., Inc.,
432 F. Supp. 2d 1319, 1334 (S.D. Fla. 2006) (quoting Montgomery Ward & Co., 311 U.S. 243,
251 (1940)).
“A judge should grant a motion for a new trial when ‘the verdict is against the clear weight
of the evidence or will result in a miscarriage of justice, even though there may be substantial
evidence which would prevent the direction of a verdict.’” Lipphardt v. Durango Steakhouse of
Case 1:21-cv-21940-BB Document 612 Entered on FLSD Docket 02/20/2026 Page 6 of 8

Case No. 21-cv-21940-BLOOM/Torres
7
Brandon, Inc., 267 F.3d 1183, 1186 (11th Cir. 2001) (quoting Hewitt v. B.F. Goodrich Co., 732
F.2d 1554, 1556 (11th Cir. 1984)). “In assessing evidentiary rulings already made by this Court,
the question is whether the exclusion or admission of evidence affected Defendant’s substantial
rights.” Sec. & Exch. Comm’n v. Complete Bus. Sols. Grp., Inc., 608 F. Supp. 3d 1231, 1239 (S.D.
Fla. 2022). Further, “[b]ecause it is critical that a judge does not merely substitute his judgment
for that of the jury, ‘new trials should not be granted on evidentiary grounds unless, at a minimum,
the verdict is against the great—not merely the greater—weight of the evidence.’” Lipphardt, 267
F.3d at 1186.
“[G]ranting motions for new trial touches on the trial court’s traditional equity power to
prevent injustice and the trial judge’s duty to guard the integrity and fairness of the proceedings
before [her].” Sherrod v. Palm Beach Cnty. Sch. Dist., 237 F. App’x 423, 424 (11th Cir. 2007)
(quoting Christopher v. Florida, 449 F.3d 1360, 1366 n.4 (11th Cir. 2006)). Accordingly, “motions
for a new trial are committed to the discretion of the trial court.” Montgomery v. Noga, 168 F.3d
1282, 1295 (11th Cir. 1999); Steger v. General Elec. Co., 318 F.3d 1066, 1081 (11th Cir. 2003)
(citing Deas v. PACCAR, Inc., 775 F.2d 1498, 1503 (11th Cir. 1985)).
III. 	DISCUSSION
After a careful review of the parties’ respective arguments, the Court finds that the Motion
must be denied. The grounds for relief that Tesla relies upon are virtually the same as those Tesla
put forth previously during the course of trial and in their briefings on summary judgment—
arguments that were already considered and rejected. Furthermore, Tesla does not present
additional arguments or controlling law that persuades this Court to alter its earlier decisions or
the jury verdict. Therefore, because the Court finds that the evidence admitted at trial more than
supports the jury verdict and does not find that it committed any error affecting Tesla’s substantive
Case 1:21-cv-21940-BB Document 612 Entered on FLSD Docket 02/20/2026 Page 7 of 8

Case No. 21-cv-21940-BLOOM/Torres
8
rights, the interest of justice does not require the grant of a new trial or judgment in Tesla’s favor
on either Count I, Count II, or the jury verdict regarding punitive damages.
IV. 	CONCLUSION
Accordingly, it is ORDERED AND ADJUDGED as follows:
1. 	Tesla’s Amended Renewed Motion for Judgment as a Matter of 	Law or,
Alternatively, Motion for a New Trial, ECF No. [591], is DENIED.
2. 	The Clerk of Court is directed to CLOSE this case.
DONE AND ORDERED in Chambers at Miami, Florida, on February 19, 2026.
_________________________________
BETH BLOOM
UNITED STATES DISTRICT JUDGE
cc: 	counsel of record
Case 1:21-cv-21940-BB Document 612 Entered on FLSD Docket 02/20/2026 Page 8 of 8