Wright v. Carroll – Sudden Emergency Defense in Motor Vehicle Crashes

In some lawsuits stemming from motor vehicle crash-related injuries, defendants can successfully argue the “sudden emergency doctrine” to avoid liability.
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This legal principle allows that when a driver is faced with a sudden and unexpected circumstance that is not of his own creation, leaving little time for contemplation, he will not be negligent for injuries resulting so long as the actions taken were reasonable in the context of that emergency – even if, in hindsight, he made the wrong decision.

However, this is not to say that an emergency alone automatically relieves a driver of liability for his actions, as the recent case of Wright v. Carroll well illustrates.

Our trucking accident lawyers in Charlotte understand in this case, the trucker/employer raised the sudden emergency doctrine defense with regard to a crash that severely injured a woman properly stopped at an intersection.

Litigation was a lengthy process resulting in two trials that both ended favorably for the trucker. However, the Kentucky Supreme Court ruled these findings improper, as the sudden emergency doctrine was inapplicable from the start. Other errors occurred at the trial court level as well that unfairly prejudiced the plaintiff. Ultimately, the state high court ruled the case should be remanded only for determination of damages, which plaintiff was rightfully owed.

According to court records, a trucker was driving his tractor-trailer south on a two-lane road when he neared a blind curve that is is followed closely by an intersection with a four-way stop. At the curve, a warning sign noted the upcoming intersection. The trucker had traveled this route many times. He knew about the intersection in question. Still, he testified he didn’t anticipate encountering other vehicles stopped at that intersection as he approached.

Unfortunately, he did not encounter an empty intersection. Several other vehicles were in the lane ahead of him, waiting to turn left. He slammed onto the brakes and steered his truck into a ditch so he would not rear-end those vehicles. The brakes locked, and there were skid marks for 100 feet prior to where the tractor came to a rest. However, the action caused his trailer to swing into the northbound lane, striking a woman as she said in her vehicle. She suffered serious injury to both legs as a result.

No one disputed the injured woman, later the plaintiff, had no fault in the crash. In her ensuing lawsuit, she alleged negligent operation and maintenance of the truck proximately caused her injuries.

At the first trial, the jury was instructed on the sudden emergency doctrine, and returned a verdict in favor of the trucker. On appeal, the higher court ruled the sudden emergency doctrine was wrongfully applied, as cars stopped properly at an intersection shouldn’t be considered an “emergency” the trucker could not have anticipated. The verdict was reversed and the case remanded for retrial.

At the second trial, the trucker argued the accident was the result of an “unforeseen circumstance,” and he tried his best to avoid a collision. This time, the jury wasn’t instructed on the sudden emergency doctrine. However, they were also not told defendant had a duty to stay in his lane. Again, jury returned a verdict in favor of defendant.

The appellate court this time ruled trial court should have granted plaintiff’s motion for a directed verdict and should only have retried the issue of damages. The state supreme court was asked to provide review.

The sufficiency of evidence in the case, the justices ruled, meant that a directed verdict would have been the appropriate route. Thus, the case was remanded to trial court to resolve solely the issue of damages owed plaintiff.

Contact the Carolina injury lawyers at the Lee Law Offices by calling 800-887-1965.

Additional Resources:
Wright v. Carroll, Oct. 23, 2014, Kentucky Supreme Court

More Blog Entries:
Three Charlotte Residents Killed in South Carolina Collision, Oct. 5, 2014, Charlotte Car Accident Lawyer Blog

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