Harris v. Meadows
477 So. 2d 374 (1985)
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Rule of Law:
In a jurisdiction following the doctrine of contributory negligence, a plaintiff's failure to take reasonable evasive action, such as applying brakes with full force to avoid a collision, can constitute sufficient evidence for a jury to find the plaintiff contributorily negligent, thereby serving as a complete bar to recovery.
Facts:
- Carol P. Harris was driving east in the far-right lane of a five-lane street.
- Dora Stubbs Meadows was in the center turn lane, preparing to make a left turn across Harris's path of travel.
- As Harris approached, Meadows began her left turn, moving into the path of Harris's vehicle.
- Harris testified that she blew her horn, slowed down, and moved slightly to the right.
- Harris also testified that she did not apply her brakes hard or attempt to come to a complete stop, hoping Meadows might clear her path.
- Meadows's vehicle then collided with the left side of Harris's vehicle.
- As a result of the collision, Harris suffered a cervical sprain and a hip contusion.
Procedural Posture:
- Carol P. Harris sued Dora Stubbs Meadows in an Alabama trial court, alleging negligence and wanton conduct.
- At the close of evidence, the trial court dismissed the wanton conduct count upon a motion by Meadows.
- At trial, Meadows admitted negligence but raised the affirmative defense of contributory negligence.
- The jury returned a verdict in favor of the defendant, Meadows.
- The trial court entered a final judgment on the jury's verdict.
- The trial court denied Harris's subsequent motion for a new trial.
- Harris, as the appellant, appealed the judgment to the Supreme Court of Alabama, with Meadows as the appellee.
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Issue:
Does a plaintiff-driver's testimony admitting they did not brake hard to avoid a collision constitute sufficient evidence for a jury to find the driver contributorily negligent?
Opinions:
Majority - Almon, Justice
Yes. A driver's testimony admitting a failure to brake hard is sufficient evidence for a jury to find contributory negligence. The court defers to the jury's verdict, as it is presumed correct unless it is completely unsupported by evidence. In this case, Harris's own testimony, where she stated, 'I didn't really come down on my brakes in an attempt to stop' and answered 'No, sir' when asked if she ever tried to 'mash [her] brakes to the floor,' provided a sufficient evidentiary basis for the jury's conclusion. The jury could reasonably find that Harris failed to act as a prudent person would under the circumstances to avoid the collision. While acknowledging the harshness of the contributory negligence doctrine, the court affirmed that it is a firmly established principle in Alabama jurisprudence, and there was no reversible error in the jury's application of it.
Analysis:
This decision powerfully illustrates the unforgiving nature of the contributory negligence doctrine, which acts as a complete bar to a plaintiff's recovery if they are found to be at fault in any degree. Unlike the more common comparative negligence standard, this ruling confirms that in Alabama, a plaintiff's failure to take all reasonable actions for their own safety, even when a defendant is admittedly negligent, can result in a total loss of their claim. The court's deference to the jury's finding on this factual issue reinforces the high burden on plaintiffs to prove they were entirely free from fault. This case serves as a stark reminder of the significant doctrinal differences between jurisdictions and the potentially dispositive impact of a plaintiff's conduct on their ability to recover damages.
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