The court ruled in this fashion after finding that it was
possible for the jury to determine that the Defendant was negligent but that
his negligence was not the factual cause of a fatal accident.
According to the Opinion, the Plaintiffs, Erika Steudler and
Victor Resto, were walking along a road in Monroe County when Resto was struck
by a motor vehicle driven by the Defendant.
The court noted that the accident occurred at night on a
country back road with no street lighting.
Neither Plaintiff was carrying a flashlight at the time of the
accident.
Plaintiff Steudler did not see the accident but felt Resto
brush against her the darkness when he was thrown in the air.
Steudler filed a lawsuit against the Defendant seeking
emotional damages due to witnessing the accident while Resto’s estate filed a
wrongful death claim.
As noted, the matters proceeded to trial where the jury
found the Defendant negligent but also found that his actions were not the
factual cause of the Plaintiffs’ injuries.
In the post-trial motions, the Plaintiffs asserted that the verdict
was against the weight of the evidence and shocking to one’s sense of
justice. The Plaintiffs argued that,
because the jury found that the Defendant was negligent, the jury should have
found that he was also the factual cause of their injuries since it was
undisputed that Resto died from the accident.
The court ruled that a verdict is not against the weight of
the evidence simply because the evidence at trial was conflicting or that a
reasonable fact-finder could have decided the case in favor of either
party.
The trial court distinguished this case from the line of
cases which suggest that when a Defendant is found negligent and both parties
admit that there was some injury, then the Defendant must be found to have
caused at least some portion of the injuries alleged. Here, the court noted that the most
distinguishable factor between that line of cases and this case was the issue
of the Plaintiffs’ contributory negligence.
The court noted that, in the line of cases cited the Plaintiffs, the Defendants
had admitted negligence and there was no difference in opinion that the
Defendants’ negligence had caused those accidents, which cause some personal
injury.
In the Steudler
matter, the Defendant never admitted negligence and there were claims of
contributory negligence pursued. The
defense argued that the sole cause of the accident was the Plaintiffs’ own acts
or omissions. It was the Defendant’s
defense that he operated his vehicle within the posted speed limit, stayed
within his lane of travel, and never saw the Plaintiffs prior to the
impact.
The court also noted that the parties presented experts with
different opinions on the theory of the cause of the accident in this matter.
In the end, the court found that the jury’s verdict in this
matter could have been based upon the jury’s belief that Resto was in the
roadway, together with Steudler, and that, if he was not, he may not have been
struck and killed.
As such, the court denied the Plaintiff’s request for a new
trial under the case presented.
Anyone wishing to review a copy of this decision may click
this LINK.
Source: “Digest of Recent Opinions” Pennsylvania Law Weekly (April 10, 2018).
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