Monday, March 25, 2013

General Motors Corp. v. Sanchez case brief

General Motors Corp. v. Sanchez case brief
997 S.W.2d 584 (Tex. 1999)

Defendant car company appealed from a judgment of the Court of Appeals for the Fourth District of Texas that rendered judgment for actual and punitive damages for plaintiff family of decedent in their action for negligence and strict liability.

OVERVIEW: Plaintiff family of decedent sued defendant car company, alleging negligence and strict liability in the death of decedent. The trial court jury found that decedent was 50 percent responsible for the accident, but the trial court disregarded this finding. The court of appeals held that the decedent's responsibility for the accident that resulted in his death should not be compared with defendant's responsibility because decedent's actions merely amounted to the failure to discover or guard against a product defect. The court of appeals awarded actual and punitive damages to plaintiffs. Defendant appealed.

The court reversed the judgment of the court of appeals and rendered judgment for plaintiffs' actual damages, as reduced by the jury's comparative responsibility finding. The court held that comparative responsibility applied in this case because there was evidence that decedent was negligent apart from the mere failure to discover or guard against a product defect.

-Punitive damages could not be awarded because the evidence was insufficient to support a finding of gross negligence by defendant.
-The plaintiffs are entitled to punitive damages if they established all elements of gross negligence. -Broadly speaking, gross negligence is the breach of duty involving an extreme degree of risk, considering the probability and magnitude of the potential harm to others (an objective element) when the actor has actual awareness of the risk involved but nevertheless proceeds in conscious indifference to the rights, safety, or welfare of others (a subjective element).
-Evidence of gross negligence is legally sufficient if, considered as a whole in the light most favorable to the prevailing party, it rises to a level that would enable reasonable and fair-minded people to differ in their conclusions.
-Some evidence of simple negligence is not evidence of gross negligence; conversely, some evidence of care does not defeat a gross negligence finding.

OUTCOME: The court reversed and rendered judgment to reduce actual damages by the jury's finding of comparative responsibility, and to allow no recovery for punitive damages. The court held that comparative responsibility applied in strict liability when decedent's negligence was more than the failure to discover or guard against a product defect and that punitive damages were not appropriate when there was no gross negligence by defendant car company.

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