Manning v. Brown
91 N.Y.2d 116, 689 N.E.2d 1382, 667 N.Y.S.2d 336 (1997)
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Rule of Law:
A plaintiff is precluded from recovering for personal injuries when those injuries are a direct result of their knowing participation in a serious criminal act.
Facts:
- Plaintiff Christina Manning and defendant Karla Amidon, both high school students without driver's licenses, were together on the evening of April 21, 1993.
- Amidon found a set of car keys hidden in the console of a vehicle belonging to defendants Ralph and Julie Brown.
- Amidon started the car and invited Manning to join her for a ride, which Manning accepted.
- Manning and Amidon took turns driving the car.
- While Manning was driving, Amidon informed her that the car had been stolen, but Manning continued to drive.
- After switching places again, with Amidon driving, Manning suggested they adjust the car radio back to the owner's station to conceal their use of the car.
- While attempting to adjust the radio at Manning's suggestion, Amidon took her eyes off the road, lost control of the vehicle, and collided with a pole, injuring Manning.
Procedural Posture:
- Plaintiff Christina Manning filed a negligence action against defendants Karla Amidon and the Browns in the New York Supreme Court (the state's trial court).
- Following discovery, all defendants moved for summary judgment to dismiss the complaint.
- The Supreme Court granted the defendants' motions for summary judgment, dismissing Manning's complaint.
- Manning (appellant) appealed the dismissal to the Appellate Division of the Supreme Court (the intermediate appellate court).
- The Appellate Division affirmed the trial court's grant of summary judgment.
- The Court of Appeals (the state's highest court) granted Manning leave to appeal.
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Issue:
Does a plaintiff's knowing participation in the unauthorized use of a motor vehicle preclude her from recovering for injuries that are a direct result of that illegal conduct?
Opinions:
Majority - Ciparick, J.
Yes. A plaintiff's knowing participation in the unauthorized use of a motor vehicle precludes recovery for injuries directly resulting from that conduct. The court applies the public policy doctrine from Barker v Kallash, which denies judicial relief to those injured in the course of committing a serious criminal act. The court uses a two-part inquiry: (1) whether the plaintiff's conduct was a serious violation of the law, and (2) whether the injuries were a direct result of that violation. Here, the court found that joyriding by unlicensed teenagers is an inherently hazardous activity that poses a grave risk to the public, thus qualifying as a serious violation, not a minor dereliction. Furthermore, the plaintiff's injuries were a direct result of the illegal act, as the accident occurred when her accomplice was distracted while attempting to conceal their crime at the plaintiff's suggestion. Therefore, public policy bars the plaintiff's recovery.
Analysis:
This decision solidifies the application of the public policy doctrine established in Barker v Kallash, which prevents a plaintiff from profiting from their own serious wrongdoing. By categorizing joyriding by unlicensed minors as a 'serious' criminal violation, the court sets a precedent that extends the doctrine beyond inherently violent or felonious acts. This ruling clarifies that the 'seriousness' of an offense can be determined by the danger it poses to the public, not just its classification in the penal code. The case serves as a strong barrier against negligence claims brought by co-participants in hazardous illegal activities, reinforcing that the courthouse doors are closed to those seeking compensation for injuries that are the direct consequence of their own criminal conduct.
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