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Knell v. Feltman

United States Court of Appeals District of Columbia Circuit
174 F.2d 662 (1949)
ELI5:

Rule of Law:

In the District of Columbia, a concurrent tortfeasor who is not an intentional wrongdoer may seek and enforce contribution from another concurrent tortfeasor, even if the original plaintiff did not obtain a judgment against that other tortfeasor.


Facts:

  • Evelyn Langland and her husband were guest passengers in an automobile owned and operated by Kenneth E. Knell.
  • While driving in the District of Columbia, Knell's car collided with a taxicab owned by Ralph L. Feltman and operated by his employee.
  • As a result of the collision, Mrs. Langland sustained serious injuries.
  • The collision was caused by the concurrent negligence of both Knell and Feltman's driver.

Procedural Posture:

  • Evelyn Langland and her husband sued Ralph L. Feltman in the District Court for the District of Columbia (trial court).
  • Feltman filed a third-party complaint against Kenneth E. Knell, seeking contribution for any damages awarded to the Langlands.
  • Knell answered the third-party complaint and filed a counterclaim against Feltman for his own personal injuries.
  • The Langlands did not amend their complaint to add Knell as a defendant.
  • A jury, answering special interrogatories, found that both Feltman's driver and Knell were concurrently negligent and that their negligence contributed to the collision.
  • The trial court entered a judgment for the Langlands against Feltman for $11,500.
  • The trial court then entered a judgment in favor of Feltman against Knell for contribution in the amount of $5,750.
  • Knell (appellant) appealed the judgment for contribution to the United States Court of Appeals for the District of Columbia Circuit.

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Issue:

Does a right of contribution exist between concurrent, unintentional tortfeasors where the injured plaintiff secured a judgment against only one of them?


Opinions:

Majority - Wilbur K. Miller

Yes. The right of contribution exists between concurrent, unintentional tortfeasors regardless of whether the plaintiff obtains a judgment against both. The court explicitly adopts the rule that when parties are not intentional or willful wrongdoers, contribution may be enforced. The court reasons that the right to seek contribution belongs to the tortfeasor who has been forced to pay, and its existence should not logically depend upon the selection of defendants made by the plaintiff. Allowing the plaintiff's choice to control would be subject to whim or collusion. Furthermore, Federal Rule of Civil Procedure 14(a) allows a defendant to bring a third-party defendant into the action who 'is or may be liable' for part of the plaintiff's claim, and the third-party defendant is bound by the adjudication of liability even if the plaintiff does not amend the complaint to assert a claim directly against them.



Analysis:

This decision formally establishes the modern rule of contribution among unintentional tortfeasors in the District of Columbia, rejecting the old, harsh common-law rule that barred it entirely. It clarifies that the right to contribution is an independent claim belonging to the tortfeasor who paid and is not contingent on the plaintiff's litigation strategy. The case also highlights the procedural mechanism of impleader under Federal Rule of Civil Procedure 14(a) as the proper vehicle for a defendant to assert a contribution claim within the original lawsuit, thereby promoting judicial efficiency by resolving all related liabilities in a single action.

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