Thursday, January 31, 2013

Lyons v. Midnight Sun Transportation Services, Inc. case brief

Lyons v. Midnight Sun Transportation Services, Inc. case summary
928 P.2d 1202 (Alaska 1996)
Tort Law

PROCEDURAL HISTORY: Appellant personal representative challenged a decision from the Superior Court of the State of Alaska, Third Judicial District, which found that appellee trucker was negligent, but that his negligence was not a legal cause of the accident. The personal representative contended that giving the sudden emergency instruction was error and that the trucker was speeding and driving negligently.

-The decedent was killed when she pulled out of a parking lot and was broadsided by the trucker.
-The truck was asserted to be speeding. 

-The court concluded that the sudden emergency instruction was generally useless because with or without an emergency, the standard of care was still of a reasonable person under the circumstances.

-The court agreed with the the jury, which decided that the trucker was negligent and not exercising the care and prudence a reasonable person would exercise under the circumstances.
-The court also found that the personal representative's claims were defeated by a lack of causation, as the trucker's negligence was not the accident's legal cause, and the court could not say that the jury's lack of causation finding was unreasonable.
-The court asserted that a reasonable jury could have concluded, based on expert testimony, that the decedent caused the accident by abruptly pulling out in front of the trucker and that the trucker's negligence was not a contributing factor.
-The court opined that with the element of causation lacking, even the most egregious negligence could not result in liability.
-The court held that error in giving the instruction was harmless and affirmed the decision.

The sudden emergency doctrine is a rule of law which states that a person confronted with a sudden and unexpected peril, not resulting from that person's own negligence, is not expected to exercise the same judgment and prudence the law requires of a person in calmer and more deliberate moments. The person confronted with the imminent peril must, however, act as a reasonable person would under the same conditions.

CONCLUSION: The court affirmed the trial court's decision that the trucker was not at fault in the accident, but that the primary cause was the decedent pulling out in front of the trucker, and that the giving of the sudden emergency instruction was harmless error.

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