Charbonneau v. MacRury
153 A. 457 (1931)
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Rule of Law:
A minor charged with negligence is not held to the adult standard of care but rather to the standard of a reasonably prudent person of like age, intelligence, and experience under the same circumstances.
Facts:
- Elwood F. MacRury was a 17-year-old minor.
- After working at his father's mill for a full day, MacRury drove his father's car to attend a dance and then drove other individuals home.
- The entire trip covered a significant distance and occurred late at night.
- While driving, MacRury fell asleep at the wheel.
- The car driven by MacRury collided with another vehicle, resulting in the death of its driver, Joseph Charbonneau.
- The Plaintiff is the administrator of Charbonneau's estate.
Procedural Posture:
- The plaintiff, as administrator of the deceased's estate, sued the minor defendant, Elwood F. MacRury, for negligence in a New Hampshire trial court.
- At the conclusion of the trial, the judge instructed the jury that MacRury's conduct should be judged 'according to the average conduct of persons of his age and experience.'
- The jury returned a verdict in favor of the defendant, MacRury.
- The plaintiff, as appellant, appealed the judgment to the Supreme Court of New Hampshire, challenging the jury instruction as an error of law.
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Issue:
Is a minor defendant in a negligence action held to the same standard of reasonable care as an adult, or is their conduct to be judged based on the standard of a reasonable person of similar age, intelligence, and experience?
Opinions:
Majority - Snow, J.
No. A minor defendant in a negligence action is not held to the adult standard of care; their conduct is judged by the standard of care reasonably expected of a child of like age, intelligence, and experience. The court reasoned that the universal standard of care is 'reasonable care under all the circumstances.' A minor's age and stage of development are crucial circumstances that must be considered. It would be inconsistent and arbitrary to recognize a child's immaturity when they are a plaintiff claiming contributory negligence but to ignore it when they are a defendant charged with primary negligence. The law does not demand that a child act with a level of judgment or experience they do not possess. Therefore, instead of creating a separate standard, the court treats infancy as a factor to be weighed by the jury when applying the general rule of reasonable conduct, just as it would consider an adult's physical infirmities.
Analysis:
This decision is significant for establishing a unified standard of care for minors in negligence cases, regardless of whether they are the plaintiff or defendant. It rejects the minority view that would hold a minor defendant to an adult standard of care, harmonizing the rule with the well-established principle used in contributory negligence cases. By treating a minor's age and experience as 'circumstances' rather than creating a separate legal standard, the court provides a flexible framework for juries to assess a minor's fault based on their actual capacity. This approach influences subsequent tort law by reinforcing that the 'reasonable person' standard must be adapted to the specific attributes of the actor, particularly the recognized limitations of youth.
