Lexplug logoLexplug

McDonald v. Robinson

Supreme Court of Iowa
224 N.W. 820 (1929) (1929)
ELI5:

Rule of Law:

When the separate and independent negligent acts of two or more persons concur to produce a single, indivisible injury, the actors may be held jointly and severally liable as joint tortfeasors, even without a common design or concerted action.


Facts:

  • Robinson was driving his car westerly on Avenue G.
  • Max Padzensky was driving another car northerly on Fourth Street.
  • The two cars collided in the middle of the intersection.
  • The collision caused the cars to become interlocked and veer towards the northwest corner of the intersection.
  • The Padzensky car struck McDonald, a pedestrian, near the curbing.
  • McDonald was knocked down and dragged under the car for 56 feet, suffering serious and permanent injuries.

Procedural Posture:

  • McDonald (appellee) filed a lawsuit in an Iowa trial court against Robinson (appellant) and Padzensky.
  • The petition alleged that McDonald's injury resulted from the concurrent negligence of both drivers.
  • Robinson argued at every stage of the trial court proceeding that there was a misjoinder of causes of action and of parties.
  • Following a trial, a judgment was entered against Robinson.
  • Robinson (as appellant) appealed the trial court's judgment to the Supreme Court of Iowa.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Do the separate, negligent acts of two drivers that concurrently cause a collision resulting in a single, indivisible injury to a third party constitute a misjoinder of parties if the drivers are sued together as joint tortfeasors?


Opinions:

Majority - Stevens, J.

No. When the negligent acts of two or more parties concur to cause a single, indivisible injury, it is not a misjoinder to sue them together as joint tortfeasors. The court held that a common intent, purpose, or design is not essential for joint liability to exist. The controlling principle is that if the acts of multiple persons concur in contributing to an accident that would not have happened otherwise, the injured party may sue the actors jointly or severally. In this case, the jury could find that the injury to McDonald would not have occurred but for the concurrence of both drivers' negligence, resulting in an indivisible injury for which they can be held jointly liable.



Analysis:

This decision solidifies the 'single indivisible injury' rule for establishing joint tortfeasor liability in cases of concurrent but independent negligence. It explicitly rejects the older requirement of a 'common design' or concerted action, thereby broadening the circumstances under which multiple defendants can be joined in a single lawsuit. This approach streamlines litigation for plaintiffs injured by multiple negligent actors, preventing them from having to file separate, complex lawsuits where the harm is indivisible and causation is intertwined. The ruling is significant for tort law as it clarifies the distinction between concurrent acts causing a single injury and separate, independent acts causing divisible harms (like in some nuisance cases).

🤖 Gunnerbot:
Query McDonald v. Robinson (1929) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.
Locked
Subscribe to Lexplug to chat with the Gunnerbot about this case.

Unlock the full brief for McDonald v. Robinson