This section contains the nature of the case and procedural background.

Halloran (P) was injured when a can of Freon he was heating to enable him to put it in an automobile air conditioner exploded. P was heating the can by placing it in a water-filled coffee can and heating the water with an immersion coil. Virginia Chemicals (D), the company which packaged and sold the Freon offered evidence that P had used this method of heating cans of Freon in the past, ignoring the warnings on the cans' labels. The lower courts excluded the evidence on the principle that evidence of a party's prior instances of carelessness cannot be used to prove carelessness on the occasion in question. D appeals the judgment in P's favor.

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