McCall v. Wilder
1995 Tenn. LEXIS 746, 913 S.W.2d 150 (1995)
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Rule of Law:
A driver who causes an accident due to a sudden loss of consciousness or physical capacity may be found negligent if the driver had prior knowledge of a medical condition that made such an incapacitation reasonably foreseeable.
Facts:
- James Robert Ratley, Sr. had a known seizure disorder which caused loss of consciousness.
- Ratley had experienced seizures prior to the day of the accident.
- On December 12, 1990, while driving his vehicle, Ratley suffered a seizure.
- Ratley lost control of his vehicle and collided head-on with a vehicle driven by Lisa A. McCall.
- The collision resulted in personal injury to McCall and damage to her vehicle.
- A medical evaluation after the accident revealed Ratley had a brain tumor in a region of the brain that made him susceptible to seizures.
Procedural Posture:
- Lisa A. McCall sued Edgar A. Wilder, administrator of the estate of James Robert Ratley, Sr., in the Blount County General Sessions Court.
- After a default was entered against the defendant, the case was appealed to the Blount County Circuit Court (trial court).
- The defendant moved for summary judgment, arguing the accident was an unforeseeable sudden emergency.
- The Circuit Court granted summary judgment in favor of the defendant.
- McCall, as appellant, appealed the decision to the Tennessee Court of Appeals (intermediate appellate court).
- In a divided decision, the Court of Appeals affirmed the trial court's grant of summary judgment.
- McCall, as appellant, sought and was granted permission to appeal to the Supreme Court of Tennessee (highest court).
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Issue:
Does a driver who causes an accident due to a sudden, medically-induced loss of consciousness breach the duty of reasonable care if the driver had prior knowledge of the medical condition that could cause such an incapacitation?
Opinions:
Majority - Justice White
Yes. A driver who knows of a medically incapacitating disorder breaches the duty of reasonable care by driving if a reasonably prudent person could foresee that doing so poses an unreasonable risk of harm to others. The defense of sudden, unforeseeable loss of consciousness is not available when the driver was aware of facts sufficient to make the incapacitation foreseeable. Here, it was stipulated that the decedent, Ratley, knew he suffered from a seizure disorder that caused loss of consciousness. This knowledge creates a question of fact for a jury as to whether it was reasonably foreseeable that an accident might occur if he experienced a seizure while driving, and therefore whether his decision to drive constituted a breach of his duty of care.
Analysis:
This decision establishes the modern standard in Tennessee for negligence cases involving a driver's sudden medical incapacitation. It rejects an automatic 'sudden emergency' defense and instead adopts a foreseeability-based standard that aligns with the majority of other jurisdictions. The ruling clarifies that a driver's prior knowledge of a potentially incapacitating condition creates a jury question regarding the reasonableness of their decision to drive. This makes it more difficult for defendants with known medical conditions to obtain summary judgment and ensures that the specific facts surrounding their knowledge and the nature of their condition will be scrutinized at trial.
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