Lyons v. Midnight Sun Transportation Services, Inc.
928 P.2d 1202 (1996)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The sudden emergency jury instruction is disapproved for future use as it is a redundant and potentially confusing appendage to the general standard of negligence, which is to act as a reasonable person would under the circumstances.
Facts:
- Esther Hunter-Lyons was driving her Volkswagen van when she pulled out of a parking lot onto Arctic Boulevard in Anchorage.
- David Jette, an employee of Midnight Sun Transportation Services, Inc., was driving a truck south in the right-hand lane of Arctic Boulevard.
- Hunter-Lyons pulled out in front of Jette's oncoming truck.
- Jette braked and steered to the left in an attempt to avoid a collision.
- Despite Jette's evasive maneuvers, Hunter-Lyons continued to pull further into the traffic lane.
- Jette's truck struck Hunter-Lyons's van broadside, resulting in her death.
- Expert testimony at trial was conflicting regarding Jette's speed and whether the accident was avoidable.
Procedural Posture:
- David Lyons, the deceased's husband, filed a negligence lawsuit against David Jette and Midnight Sun Transportation Services, Inc. in an Alaska trial court.
- During the trial, the court gave the jury an instruction on the sudden emergency doctrine over Lyons's objection.
- The jury returned a verdict finding that Jette had been negligent, but that his negligence was not a legal cause of the accident, resulting in a judgment for the defendants.
- Lyons, as the appellant, appealed the judgment to the Supreme Court of Alaska, challenging the trial court's decision to give the sudden emergency instruction.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a trial court's jury instruction on the sudden emergency doctrine constitute reversible error when the jury finds the defendant negligent but concludes that this negligence was not the legal cause of the plaintiff's harm?
Opinions:
Majority - Per Curiam
No, the jury instruction on the sudden emergency doctrine did not constitute reversible error in this case. Although the court disapproves of the instruction for future use, any error in giving it here was harmless because the jury found the defendant was negligent but that his negligence was not the legal cause of the accident. The sudden emergency instruction relates only to the standard of care (the breach element of negligence), not to causation. The jury's separate finding on the lack of causation was supported by evidence suggesting the accident would have happened regardless of Jette's negligence and was primarily caused by Hunter-Lyons pulling into traffic. While the sudden emergency doctrine is not inherently incompatible with comparative fault, it is redundant to the general standard of care, which requires a person to act reasonably under all circumstances, including an emergency. Therefore, to avoid juror confusion and give undue weight to one party's argument, the instruction should no longer be used except in rare and peculiar circumstances.
Analysis:
This decision prospectively eliminates the use of the sudden emergency instruction in Alaska, aligning the state with a modern trend of simplifying negligence law. By holding that the instruction is redundant to the 'reasonable person under the circumstances' standard, the court streamlines jury deliberations, preventing confusion and the potential for a defendant to be excused from the ordinary standard of care. This ruling clarifies that an emergency is not a separate legal defense but is merely one of the circumstances a jury should consider when evaluating the reasonableness of a party's conduct. The case thus reinforces the primacy of the core elements of negligence—duty, breach, causation, and harm—and simplifies the analysis of the breach element.
