Lyons v. Midnight Sun Transportation Services, Inc.
928 P.2d 1202 · Alaska Supreme Court · 1996
Facts
Esther Hunter-Lyons was killed when her van, pulling out of a parking lot, was struck by David Jette's truck. Her husband sued for negligence, alleging Jette was speeding. The jury found Jette negligent but that his negligence was not the legal cause of the accident, leading to an appeal regarding the sudden emergency instruction given to the jury.
Issue
Was it reversible error for the trial court to instruct the jury on the sudden emergency doctrine when the jury found negligence but no causation? Should the sudden emergency instruction be generally used in future negligence cases?
Holding
The court affirmed, finding any error in giving the instruction harmless because the jury's finding of no causation rendered Jette not liable. However, the court disapproved of the sudden emergency instruction's future use, deeming it generally redundant and potentially confusing.
Rule
The sudden emergency doctrine, while not inherently incompatible with comparative negligence, is generally a useless and potentially confusing appendage to negligence law. The standard of care always requires acting as a reasonable person under the circumstances, making the instruction redundant and its future use discouraged.
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