Sullivan v. Crabtree
258 S.W.2d 782 (1953)
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Rule of Law:
In an ordinary negligence case, the doctrine of res ipsa loquitur permits, but does not compel, a jury to infer negligence from the circumstances of an accident; it does not create a mandatory presumption of negligence or shift the ultimate burden of proof to the defendant.
Facts:
- The defendant, Crabtree, was employed as a driver for the Hoover Motor Express Company.
- Crabtree permitted Robert Sullivan to ride as a guest in the cab of his tractor-trailer truck.
- While driving on a paved highway down a mountain in clear, dry weather, another truck overtook and passed Crabtree's vehicle.
- Immediately after being passed, Crabtree's truck suddenly swerved from the right side of the road to the left.
- The truck ran off the left shoulder of the road and overturned down a steep embankment, crushing Sullivan to death.
- Crabtree could not definitively explain why he lost control of the truck, speculating that it could have been caused by loose gravel, a brake failure, or a disconnected hose.
Procedural Posture:
- The parents of Robert Sullivan (plaintiffs) sued Crabtree (defendant driver) and his employer in the Circuit Court for wrongful death.
- Plaintiffs voluntarily dismissed their claim (took a nonsuit) against the employer.
- The case proceeded to a jury trial against Crabtree alone.
- The jury returned a verdict in favor of the defendant, Crabtree.
- The plaintiffs (appellants) appealed the judgment to the Tennessee Court of Appeals.
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Issue:
Does the doctrine of res ipsa loquitur, when applicable to an unexplained single-vehicle accident, require a jury to find the defendant negligent as a matter of law?
Opinions:
Majority - Felts, J.
No. The doctrine of res ipsa loquitur, in an ordinary case, merely permits a jury to infer negligence and does not compel such a finding. The court reasoned that res ipsa loquitur is a common-sense application of circumstantial evidence, meaning the facts of the occurrence may provide evidence of negligence. While the circumstances of the truck running off the road for no apparent reason brought the case within the doctrine, it did not create an irrefutable presumption of negligence. The court distinguished between three procedural effects of the doctrine: (1) a permissible inference of negligence, which the jury may accept or reject; (2) a rebuttable presumption of negligence; and (3) a shift in the ultimate burden of proof. The court held that in an ordinary case such as this, the doctrine only creates a permissible inference. Because conflicting inferences could be drawn from the evidence—that Crabtree was negligent or that the crash was an unavoidable accident due to mechanical failure—it was properly the jury's role to choose the most probable inference.
Analysis:
This case clarifies the procedural weight of the res ipsa loquitur doctrine in Tennessee negligence law, particularly in the context of motor vehicle accidents. By establishing that the doctrine typically creates only a permissible inference rather than a mandatory presumption of negligence, the decision reinforces the jury's central role as the finder of fact. This precedent makes it more difficult for a plaintiff to obtain a directed verdict in a res ipsa case, as the jury retains the discretion to reject an inference of negligence even if the defendant cannot fully explain the accident. The ruling emphasizes that the ultimate burden of persuasion remains on the plaintiff and that circumstantial evidence, even when strong, is generally for the jury to weigh.
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