Hendrix v. Burns
2012 WL 1034447, 205 Md. App. 1, 43 A.3d 415 (2012)
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Rule of Law:
The tort of battery in Maryland requires an intent to cause harmful or offensive contact, which reckless conduct alone cannot satisfy, though the doctrine of transferred intent may apply if an original intent to harm existed. In a negligence case where liability is conceded, evidence of the defendant's specific pre- or post-accident conduct or the detailed basis for a negligent entrustment claim is generally inadmissible if deemed irrelevant to damages and unfairly prejudicial.
Facts:
- On July 25, 2005, Charles Robert Burns was driving a Jeep Cherokee, owned by his wife Candice Marie Burns, south on Belair Road.
- Charles Robert Burns had a history of substance abuse, a criminal record, and driving violations, and had consumed alcohol on the day of the accident.
- Immediately prior to the collision, Charles Robert Burns was engaged in a "road rage" incident with another driver (a Toyota Camry), speeding erratically and attempting to catch up with the Camry.
- At the intersection of Belair Road and Glen Park Road, Charles Robert Burns failed to stop for a red traffic light.
- At the same time, Marjorie Gayle Hendrix was driving her Toyota Corolla through the intersection, having just exited a shopping center, with a green light in her favor.
- Charles Robert Burns's Jeep struck the rear driver's side of Marjorie Gayle Hendrix's Toyota, causing it to spin, and he then attempted to flee the scene.
- Marjorie Gayle Hendrix sustained injuries to her neck, shoulders, chest, and abdomen, and suffered emotional injuries, including believing she would not survive.
- Candice Marie Burns allowed Charles Robert Burns to use her Jeep Cherokee regularly, with her knowledge and permission, despite knowing his history of substance abuse and driving violations.
Procedural Posture:
- On October 22, 2007, Marjorie Gayle Hendrix sued Charles Robert Burns and Candice Marie Burns in the Circuit Court for Baltimore County, alleging battery and negligence against Mr. Burns and negligent entrustment against Mrs. Burns.
- Before trial, the Circuit Court for Baltimore County granted summary judgment in favor of Mr. Burns on the battery claim.
- Before trial, Charles Robert Burns conceded liability for negligence, and Candice Marie Burns conceded liability for negligent entrustment, leaving only the issue of damages for trial.
- Before trial, the Circuit Court for Baltimore County granted motions in limine that precluded Mrs. Hendrix from introducing evidence of Mr. Burns's intoxication, road rage, attempted flight, prior criminal convictions, and the specific facts underlying the negligent entrustment claim.
- On August 26, 2010, Mrs. Hendrix filed an amended complaint, adding allegations of intentional misconduct on the part of Mrs. Burns to the negligent entrustment count.
- On September 9, 2010, Mrs. Burns filed a motion to strike the amendments.
- On September 29, 2010 (the day trial began), the Circuit Court for Baltimore County granted Mrs. Burns’s motion to strike the portion of the complaint that had been amended.
- From September 29, 2010, to October 2, 2010, the case was tried to a jury in the Circuit Court for Baltimore County solely on the issue of damages.
- The jury returned a verdict in favor of Mrs. Hendrix for $85,000.
- Marjorie Gayle Hendrix, the appellant, noted a timely appeal from the judgment entered on the verdict to the Court of Special Appeals of Maryland.
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Issue:
1. Does the tort of battery require specific intent to cause a harmful or offensive contact to the plaintiff, and can the doctrine of transferred intent apply if the defendant's alleged intent was directed at a third party but without a specific intent to cause harmful or offensive contact? 2. In a personal injury case where the defendants have conceded liability for negligence and negligent entrustment, is evidence of the defendant driver's pre- and post-accident conduct (e.g., intoxication, road rage, attempted flight, prior criminal convictions) or the full factual basis of the negligent entrustment claim against the vehicle owner relevant to the plaintiff's damages for emotional distress, or is such evidence unfairly prejudicial and thus excludable?
Opinions:
Majority - Deborah S. Eyler, J.
No, the circuit court correctly granted summary judgment on the battery claim because there was no evidence that Charles Robert Burns intended to strike Marjorie Gayle Hendrix's vehicle. Battery requires a general intent to unlawfully invade another's physical well-being through a harmful or offensive contact, not merely reckless or wanton conduct, which differs significantly from intentional wrongdoing. The court noted that while transferred intent can apply to civil battery claims in Maryland, it was not applicable here because the evidence, even when viewed most favorably to Mrs. Hendrix, did not demonstrate that Mr. Burns intended to cause harmful or offensive contact with the primary target (the Camry driver). His actions, though indicative of anger and recklessness, did not rise to the level of intent to inflict harm. Therefore, without legally sufficient evidence of intent, either directly or through transferred intent, the battery claim could not proceed. No, the circuit court did not err or abuse its discretion by granting motions in limine to exclude certain evidence. In a case where liability for negligence and negligent entrustment is conceded and only damages are at issue, evidence of Charles Robert Burns's intoxication, "road rage" incident, attempted flight, or prior criminal convictions was not relevant to the nature or severity of Marjorie Gayle Hendrix's physical injuries or the emotional distress directly resulting from those injuries. Such after-acquired knowledge about Mr. Burns's character or specific actions, while potentially upsetting, was collateral to the injuries sustained in the accident itself. The court distinguished this from cases involving pre-impact fright or emotional distress directly flowing from the tortious act (e.g., fear of HIV transmission during surgery). Furthermore, the court ruled that if such evidence had any probative value regarding damages, it was substantially outweighed by the danger of unfair prejudice to the Burnses, as its only possible effect would have been to improperly inflame the jury and inflate the damages award. Similarly, revealing the precise nature and underlying facts of the negligent entrustment claim against Candice Marie Burns would have unnecessarily injected Mr. Burns's prior bad acts into the trial, which were irrelevant to the conceded liability and damages and highly prejudicial. The jury was adequately informed that both defendants were liable.
Analysis:
This case significantly clarifies the standard for intent required for civil battery in Maryland, explicitly distinguishing it from reckless behavior and adopting the doctrine of transferred intent but with a strict requirement for original intent to cause harm. It also provides important guidance on evidentiary matters in personal injury cases where liability is admitted. The ruling reinforces the principle that highly prejudicial evidence of a defendant's character or specific prior bad acts, even if factually true, is generally inadmissible if its probative value for determining damages is substantially outweighed by its potential to inflame the jury. This limits plaintiffs' ability to use inflammatory details to boost damage awards beyond compensation for directly caused injuries, highlighting the careful balance courts must strike between relevance and prejudice.
