Stewart v. Motts
654 A.2d 535 · Supreme Court of Pennsylvania · 1995
Facts
Plaintiff Jonathon Stewart was severely burned when gasoline he was pouring into a car's carburetor, while assisting defendant Martin Motts, backfired and exploded. A jury found for the defendant, and Stewart appealed, arguing the trial court should have instructed the jury on a 'high degree of care' for handling gasoline.
Issue
Does Pennsylvania law recognize a separate, higher standard of 'extraordinary care' for negligence cases involving dangerous instrumentalities, distinct from the standard of 'reasonable care,' such that the trial court erred by not giving a specific instruction on a 'high degree of care' for handling gasoline?
Holding
The court affirmed the lower court's decision, holding that there is only one standard of care in Pennsylvania negligence actions: 'reasonable care.' The trial court's instructions were adequate as they conveyed that reasonable care must be proportionate to the danger involved.
Rule
In Pennsylvania, there is only one standard of care in negligence actions, including those involving dangerous instrumentalities: 'reasonable care under the circumstances.' While the degree of care required varies with the danger, a 'higher degree of care' is not a separate standard but rather the application of reasonable care proportionate to the danger involved.
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