Castro v. Los Angeles County Sheriff's Dept. CA2/5

CourtCalifornia Court of Appeal
DecidedMarch 9, 2016
DocketB262516
StatusUnpublished

This text of Castro v. Los Angeles County Sheriff's Dept. CA2/5 (Castro v. Los Angeles County Sheriff's Dept. CA2/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Castro v. Los Angeles County Sheriff's Dept. CA2/5, (Cal. Ct. App. 2016).

Opinion

Filed 3/9/16 Castro v. Los Angeles County Sheriff’s Dept. CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FIVE

ERNESTO CASTRO, B262516

Plaintiff and Appellant, (Los Angeles County Super. Ct. No. BC500939) v.

LOS ANGELES COUNTY SHERIFF’S DEPARTMENT et al.,

Defendants and Respondents.

APPEAL from an order of the Superior Court of Los Angeles County, Patrick T. Madden, Judge. Affirmed. Layfield & Wallace, Philip J. Layfield for Plaintiff and Appellant. Hurrell Cantrall, Thomas C. Hurrell, Melinda Cantrall for Defendants and Respondents. Plaintiff and appellant Ernesto Castro was in a motor vehicle accident with defendant and respondent Larry Walter Reed on the 101 Freeway. Reed’s truck struck Castro’s car from behind after Castro’s car stalled in traffic. Castro brought a negligence action against Reed and Reed’s employer, defendant and respondent Los Angeles County Sheriff’s Department (LASD). The jury determined defendants were not negligent, and the trial court entered judgment in defendants’ favor. The trial court denied Castro’s subsequent motion for judgment notwithstanding the verdict. Castro argues the trial court erred in denying his motion, contending he was entitled to a presumption of negligence under the doctrine of res ipsa loquitur and defendants failed to present sufficient evidence at trial to rebut that presumption. Because Castro waived the claims he asserts on appeal by withdrawing his request for the trial court to instruct the jury on res ipsa loquitur, we affirm.

BACKGROUND About 10:55 p.m. on August 31, 2012, Castro was driving a 1971 Pontiac Firebird southbound in the far right or number four lane on the 101 Freeway. Reed, who was driving an 18-wheel truck, also was driving southbound in the number four lane on the 101 Freeway. There was a “fair amount of traffic,” but it was mostly in the left lanes and flowing well—there was “no real traffic in the right lanes.” Reed was traveling 50 miles per hour, the appropriate speed in light of the traffic conditions. He was not driving too fast for the traffic conditions, and the traffic was “all pretty much” traveling faster than his truck. As Reed was traveling in the number four lane, an SUV in front of him quickly swerved from the number four lane into the number three lane as if it was trying to go around something. Reed applied the brakes, whereupon the trailer on his truck skidded sideways and started to jackknife. He took his foot off the brakes to control the truck, and immediately regained control. As the SUV swerved, its headlights illuminated Castro’s car which Reed saw for the first time. Castro’s car was stopped directly in front of Reed’s truck in the number four lane. Reed reapplied the brakes to try to avoid hitting

2 Castro’s car, but was unsuccessful. His truck hit the back of Castro’s car at about 15 to 20 miles per hour. Reed was unsure how close he was to Castro’s car when he first saw it. At his deposition, Reed testified that he was a “good 5- to 600 yards” from Castro’s car when he first saw it and started to brake. Reed had not misjudged the degree of force he needed to apply to the brakes to avoid hitting Castro’s car. He applied 100 percent of the available brake pressure—his truck had air pressure brakes—when he first saw Castro’s car. Although he had not misjudged the degree of force he needed to apply to the brakes, Reed was unable to stop in time to avoid hitting plaintiff’s car. He did everything imaginable and possible to stop his truck. There was nothing else he could have done to prevent his truck from running into Castro’s car. Reed’s Captain at the LASD signed a report on which he commented that “unsafe speed was the primary causal factor” in the accident. The report also stated the accident was preventable. Although Reed signed the report without expressing disagreement with it, he disagreed with his Captain’s conclusion that he was traveling at an unsafe speed. He explained he was traveling under 50 miles per hour and suggested he would have been a hazard to other drivers if he had been driving slower. Castro testified traffic was heavy on the night of the accident. Traffic had stopped about 25 feet ahead of Castro, and he had applied the brakes. When applying the brakes, Castro “heard the car was having some trouble.” His car began to lose power. He thought about pulling from the number four lane to the shoulder, but did not have the opportunity because traffic was too heavy. In addition, when he looked to the right, there was an on-ramp with merging vehicles and not a shoulder. Castro decided the most reasonable course of action was to remain in the lane he was in and coast to a stop. He planned to restart his car when he came to a stop. Castro’s car had never previously stalled on the freeway. Castro’s car coasted for about 20 seconds before stopping. Castro realized his car was “clearly disabled long before” it came to a stop. When his car stopped, Castro put it in park and attempted to restart it. Castro had just restarted his car, which had been

3 stopped for about seven seconds, when Reed’s truck struck Castro’s car. Castro did not believe there was anything else he could have done to avoid the accident. On cross-examination, defense counsel asked Castro, “[A]s you’re traveling down the freeway, after you loss [sic] power in your vehicle, nothing prohibited you from parking the car on the shoulder of the road; is that true?” Castro responded, “That is correct.” On a special verdict form, the jury was asked, “Was defendant Larry Reed negligent in operating the motor vehicle owned by defendant Los Angeles County Sheriff’s Department.” The jury answered the question, “No.” The trial court entered judgment in favor of defendants. Castro filed a motion for judgment notwithstanding the verdict in which he argued there was a rebuttable presumption under the doctrine of res ipsa loquitur that Reed was negligent in striking Castro’s car from behind, which presumption defendants failed to rebut with substantial evidence. The trial court denied the motion. Castro appealed from the order denying his motion for judgment notwithstanding the verdict.

DISCUSSION Castro contends the doctrine of res ipsa loquitur applied as a matter of law in this case to create a rebuttable presumption that Reed was negligent when Reed’s truck struck Castro’s stationary vehicle from behind. Castro argues that the burden shifted to defendants to prove the accident was not caused in any part by Reed’s negligence and defendants failed to make that showing. Because Castro withdrew his request that the trial court instruct the jury on res ipsa loquitur, Castro waived his claims that Reed was presumed negligent and defendants failed to provide sufficient evidence to rebut that presumption.

I. Res Ipsa Loquitur Under the doctrine of res ipsa loquitur, “certain kinds of accidents are so likely to have been caused by the defendant’s negligence that one may fairly say ‘the thing speaks

4 for itself.’” (Brown v. Poway Unified School Dist. (1993) 4 Cal.4th 820, 825.) The doctrine “is defined by statute as ‘a presumption affecting the burden of producing evidence.’ (Evid. Code, § 646, subd.

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Bluebook (online)
Castro v. Los Angeles County Sheriff's Dept. CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/castro-v-los-angeles-county-sheriffs-dept-ca25-calctapp-2016.