Heath v. Swift Wings, Inc.
252 S.E.2d 526 (1979)
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Rule of Law:
The standard of care for negligence is an objective one, requiring an individual to act as a reasonably prudent person under the circumstances. For professionals, this standard is elevated to that of a reasonably prudent professional in that field, but it remains objective and is not subjectively tailored to the individual's specific level of training or experience.
Facts:
- Fred Heath was the pilot of a Piper 180 Arrow aircraft.
- The aircraft experienced engine roughness, potentially during an attempted takeoff.
- In response to the engine issue, Heath switched the ignition from both magnetos to a single magneto.
- An incident occurred which resulted in the plaintiff filing a negligence lawsuit against Heath.
Procedural Posture:
- Plaintiff filed a negligence lawsuit against the defendant, Fred Heath, in a state trial court.
- The case proceeded to a jury trial.
- Following the trial, a judgment was entered (presumably for the defendant, based on the plaintiff's appeal).
- Plaintiff, as appellant, appealed the judgment to the North Carolina Court of Appeals, an intermediate appellate court, alleging prejudicial errors in the trial court's jury instructions.
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Issue:
Does a jury instruction on the standard of care for a professional, such as a pilot, commit prejudicial error by defining it subjectively based on the individual's specific training and experience, rather than objectively based on a minimum standard applicable to all members of that profession?
Opinions:
Majority - Morris, Chief Judge
Yes. A jury instruction that defines the standard of care based on the individual professional's specific training and experience is a misapplication of the law and constitutes prejudicial error. The correct legal standard for negligence is objective, based on the conduct of a reasonably prudent person, or in this case, a reasonably prudent pilot. While professionals are held to a standard commensurate with their field, this standard must be a uniform minimum for all practitioners, not a variable one dependent on an individual's particular background, whether it be superior or inferior. The trial court's instruction improperly introduced a subjective standard, which has the potential to create a different standard of care for each individual, undermining the consistency of the law. The court found this error, along with the judge's unsupported characterization of the pilot's actions as an 'emergency procedure' and misstatement of the plaintiff's contentions, required a new trial.
Analysis:
This decision reinforces the fundamental tort law principle that the standard of care is objective, not subjective, even in cases involving specialized skills. It clarifies that while the quantum of care required may increase for a professional, the standard itself is not personalized to the individual's specific abilities or background. This precedent prevents a defendant with substandard training from benefiting from a lower standard of care, while also protecting a highly-skilled defendant from being judged by an unfairly elevated one. The ruling ensures a consistent and predictable minimum standard of competence for professions like aviation and serves as a strong reminder to trial courts to provide clear, evidence-based, and objective jury instructions.
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