Eddy v. McAninch
141 Colo. 223, 347 P.2d 499, 1959 Colo. LEXIS 286 (1959)
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Rule of Law:
The violation of a motor vehicle safety statute creates a rebuttable presumption of negligence, which a defendant may overcome by presenting evidence that the failure to comply was due to a sudden, unforeseeable event beyond their control and that they exercised reasonable care.
Facts:
- The defendant had purchased the automobile he was driving about a week before the accident.
- At the time of purchase, the brakes had been inspected and certified as being in good operating condition.
- The defendant had no difficulty with the brakes during the time he drove the car, up to the moment of their failure.
- On the evening of July 11, 1956, the plaintiff was a passenger in a car driven by Gordon F. Bibb, which was making a legal left turn at an intersection with a green signal.
- The defendant was approaching the intersection from the opposite direction and was following a large truck that stopped for a red light.
- When the defendant attempted to apply his brakes to stop, both the service and hand brakes suddenly failed to operate.
- To avoid colliding with the truck, the defendant swerved to the right, entered the intersection against the red light, and struck the car in which the plaintiff was a passenger.
- The collision caused injuries to the plaintiff that aggravated a pre-existing condition of osteoarthritis.
Procedural Posture:
- The plaintiff sued the defendant in the trial court for personal injuries sustained in an automobile collision.
- The case was tried before a jury, which returned a verdict for the defendant.
- The plaintiff filed motions for judgment notwithstanding the verdict and for a new trial, which the trial court overruled.
- The plaintiff, as plaintiff in error, appealed the judgment to the Supreme Court of Colorado.
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Issue:
Does a driver's violation of a motor vehicle safety statute, caused by a sudden and unforeseeable mechanical failure, constitute negligence as a matter of law?
Opinions:
Majority - Mr. Chief Justice Knauss
No. The violation of a safety statute due to a sudden mechanical failure does not constitute negligence as a matter of law; rather, it creates a presumption of negligence that the defendant can rebut. While violation of a safety ordinance is typically considered negligence per se, this is not an inflexible rule. The court reasoned that traffic ordinances must be given a reasonable construction and should not be interpreted to require the impossible. A sudden, unexpected mechanical failure, such as the brake failure here, can be a circumstance beyond the driver's control. Where a driver presents evidence that they exercised due care—in this case, by having the brakes recently inspected and having no prior warning of any defect—the violation is excusable. The defendant’s evidence was sufficient to overcome the presumption of negligence, creating a question of fact for the jury to decide.
Analysis:
This decision refines the negligence per se doctrine in Colorado by treating the violation of a safety statute due to mechanical failure as a rebuttable presumption of negligence, rather than conclusive proof. It moves away from a strict liability interpretation, allowing for an excuse defense based on unforeseeability and lack of control. This approach gives the jury the power to determine whether a defendant acted as a reasonably prudent person under the circumstances, even when a statute was technically violated. The ruling provides a pathway for defendants in similar situations to avoid liability for accidents that were truly unavoidable, balancing the strict enforcement of safety laws with principles of fairness.
