Coyne v. Peace
2004 Me. LEXIS 178, 2004 ME 150, 863 A.2d 885 (2004)
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Rule of Law:
In a negligence action, a person confronted with a sudden emergency that they did not cause is not held to the same standard of care as someone with time for deliberation, but rather to the standard of how a reasonably prudent person would have acted when faced with the same or similar emergency circumstances.
Facts:
- On March 16, 1997, Gregory Coyne and Greg Peace were snowmobiling together, with Peace following Coyne on a marked trail.
- They encountered several stopped snowmobiles and a snowgroomer, which required them to maneuver outside the regular trail path.
- As they proceeded into an intersection with a woods road, Coyne's snowmobile suddenly hit a bump or snow bank.
- Coyne was thrown from his snowmobile and landed on the trail directly in the path of Peace.
- Peace attempted to swerve to avoid hitting Coyne and was thrown from his own snowmobile in the process.
- Coyne suffered neck injuries and has ongoing health problems but has no memory of the specific cause of his injuries.
Procedural Posture:
- On March 13, 2003, Gregory Coyne filed a complaint against Greg Peace for negligence in the Superior Court of Maine, a trial court.
- The case was tried before a jury in March 2004.
- At trial, Coyne's counsel objected to the court's decision to provide the jury with an instruction on the emergency doctrine.
- The jury returned a verdict finding that Peace was not negligent.
- The trial court entered a judgment in favor of Peace based on the jury's verdict.
- Coyne (appellant) appealed the judgment to the Supreme Judicial Court of Maine, with Peace as the appellee.
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Issue:
Is it a reversible error for a trial court in a negligence case to give a jury instruction on the emergency doctrine when the facts show a defendant was forced to react to a sudden, unexpected event?
Opinions:
Majority - Alexander, J.
No. The trial court did not err by instructing the jury on the emergency doctrine. The doctrine provides that a person confronted by a sudden emergency not of their own making is judged by the standard of a reasonably prudent person acting under similar emergency circumstances, not by the standard applied to one with ample time to reflect. The court affirmed that the emergency doctrine remains valid in Maine, even after the adoption of comparative fault, and is not merely duplicative of a general negligence instruction. Because the evidence showed that Coyne was suddenly thrown into the trail directly in front of Peace, creating an unanticipated crisis, the facts squarely supported giving the emergency instruction to the jury.
Analysis:
This decision reaffirms the continued viability of the emergency doctrine in Maine as a distinct and proper jury instruction within negligence law, even under a comparative fault system. It clarifies that the doctrine is not redundant to a general negligence instruction but rather provides specific guidance for juries evaluating conduct during sudden, unforeseen events. The ruling solidifies the doctrine as a key tool for defendants whose actions, while perhaps imperfect in hindsight, were reactions to a crisis they did not create. This precedent confirms that trial courts have the discretion to issue the instruction whenever the facts suggest a party was faced with such an emergency.
