Indiana Consolidated Insurance Co. v. Mathew
402 N.E.2d 1000 (1980)
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Rule of Law:
A person confronted with a sudden emergency not of their own making is not chargeable with negligence if they act as an ordinarily prudent person would under like circumstances. Choosing to protect one's own life over property when faced with such an emergency is a reasonable course of action.
Facts:
- Robert D. Mathew and his brother, who lived across the street from each other, had an arrangement to take turns mowing both of their lawns.
- On May 1, 1976, while his brother was out of town, Mathew went to his brother's garage to use a twelve-horsepower Toro riding lawnmower.
- Mathew filled the lawnmower's gas tank about three-fourths full using a funnel.
- After filling the tank, Mathew returned to his own home for approximately twenty minutes.
- Upon returning to the garage, Mathew started the lawnmower and immediately noticed a flame in the engine area.
- He shut off the engine, opened the hood, and discovered a four-to-five-inch flame under the gas tank.
- Mathew's attempt to smother the fire with towels was unsuccessful.
- As the flames grew and the machine began spewing gasoline, Mathew, fearing the gas tank would explode, ran to his home to call the fire department, resulting in the garage being destroyed by the fire.
Procedural Posture:
- Indiana Consolidated Insurance Company, as the insurer of the homeowner, sued Robert D. Mathew in a state trial court for negligence.
- The case was tried before a judge in a bench trial.
- The trial court found that Mathew was not negligent and entered a judgment in his favor.
- The plaintiff, Indiana Consolidated Insurance Company, appealed the trial court's negative judgment to the Court of Appeals of Indiana.
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Issue:
Does an individual's conduct constitute negligence when, after a lawnmower they started in a garage suddenly catches fire, they elect to flee and call for help rather than risk personal injury by attempting to move the flaming machine?
Opinions:
Majority - Hoffman, J.
No. An individual's conduct does not constitute negligence when, faced with a sudden emergency not of their own making, they prioritize personal safety over the preservation of property. The court analyzed three separate claims of negligence. First, the court found no negligence in fueling the mower, as Mathew testified he was careful and used a funnel, and the trial court's finding on this factual issue is not to be reweighed. Second, starting a large riding mower in an open area of a garage is not negligent because garages are designed for starting motorized vehicles, and the fire was not a reasonably foreseeable event. Third, and most importantly, Mathew's failure to push the flaming mower out of the garage was excused by the sudden emergency doctrine. Confronted with a rapidly growing fire and spewing gasoline, Mathew's fear of an explosion was reasonable. His decision to retreat and call for help was the action of a prudent person under the circumstances, as the law values human life above property and does not require individuals to risk serious injury to save property.
Analysis:
This decision provides a clear application of the sudden emergency doctrine, reinforcing that the reasonably prudent person standard is adapted to the circumstances of a crisis. The court's holding emphasizes that the law does not require heroic acts that risk personal safety for the sake of protecting property. By affirming the trial court's decision, the opinion also underscores the high standard of review for an appellant appealing a negative judgment, where an appellate court will not reweigh evidence or disturb the fact-finder's credibility determinations. The case serves as a practical illustration for students of how foreseeability and the value of life versus property are weighed in a negligence analysis.
