Teply v. Lincoln
874 P.2d 584, 1994 Ida. App. LEXIS 42, 125 Idaho 773 (1994)
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Rule of Law:
Under Idaho law, unexpectedly icy road conditions do not constitute a legal excuse for violating a traffic safety statute, such as the duty to drive on the right-hand side of the road. A violation of such a statute constitutes negligence per se.
Facts:
- During an October snowfall, Douglas Lincoln was driving his pickup truck southbound on Highway 55 at a speed between forty and fifty miles per hour.
- Lincoln's truck was in excellent condition with new tires, and its bed was weighted down.
- Suddenly and without warning, the back end of Lincoln's truck slid to the left on a slick patch of road.
- Despite Lincoln's attempts to steer into the slide and straighten the vehicle, his truck slid across the centerline of the highway.
- After crossing the centerline, Lincoln's truck collided with a northbound vehicle occupied by Louis Teply, Vonda Teply, and Sondra Bryant.
- There was no evidence that the Teplys were negligent in any way.
Procedural Posture:
- The Teplys filed a negligence action against Lincoln in an Idaho district court (trial court) to recover for personal injuries and property damage.
- The case was tried before a jury.
- Over the Teplys' objection, the trial court instructed the jury that a statutory violation could be excused by circumstances beyond the party's control.
- The jury returned a verdict finding Lincoln not negligent.
- The Teplys filed a motion for a judgment notwithstanding the verdict (JNOV) and, alternatively, for a new trial, arguing the excuse instruction was incorrect and the evidence did not support the verdict.
- The district court denied both motions and entered a judgment in favor of Lincoln.
- The Teplys (appellants) appealed the denial of their motions to the Court of Appeals of Idaho, with Lincoln as the appellee.
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Issue:
Under Idaho law, do unexpectedly icy road conditions constitute a legal excuse for violating traffic safety statutes requiring a driver to stay on the right-hand side of the road?
Opinions:
Majority - Walters, Chief Judge
No. Unexpectedly icy road conditions do not constitute a legal excuse for a driver's violation of a traffic safety statute. In Idaho, the violation of a statute enacted for the protection of motorists is negligence as a matter of law, or negligence per se. A driver cannot be excused by showing they acted as a reasonably prudent person would have under the circumstances. The Idaho Supreme Court's precedent in Haakonstad v. Hoff established that 'extreme icy conditions of the road' could not serve to excuse a defendant from liability for a statutory violation. While this is a minority rule among jurisdictions, it is the controlling law in Idaho. Therefore, the evidence of icy roads was insufficient as a matter of law to excuse Lincoln's statutory violations.
Analysis:
This decision reinforces Idaho's strict adherence to the doctrine of negligence per se in the context of traffic safety statutes, following the minority rule established in Haakonstad v. Hoff. It significantly limits the defenses available to a driver who violates a traffic statute, even if the violation is caused by sudden and unforeseen weather conditions. The ruling effectively imposes a form of strict liability, holding that the risk of losing control on ice falls on the driver who crosses the centerline, rather than allowing a jury to consider whether the driver's actions were reasonable. This precedent makes it much more difficult for defendants in similar cases in Idaho to escape liability by blaming road conditions.
