Chappell v. Webb

CourtCourt of Appeals of North Carolina
DecidedAugust 6, 2024
Docket24-23
StatusPublished

This text of Chappell v. Webb (Chappell v. Webb) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chappell v. Webb, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-23

Filed 6 August 2024

Franklin County, No. 21 CVS 470

SANDRA CHAPPELL, ADMINISTRATOR OF THE ESTATE OF SUSAN RENEE CHAPPELL (deceased), Plaintiff,

v.

SHEMARO DEANN WEBB and LADOROTHY BREANNA FOREMAN, Defendants.

Appeal by defendants from judgment entered 28 April 2023 by Judge Cynthia

K. Sturges in Franklin County Superior Court. Heard in the Court of Appeals 15

May 2024.

Bennett Guthrie PLLC, by Mitchell H. Blankenship, Rodney A. Guthrie, and Joshua H. Bennett, for defendants-appellants.

White & Stradley, PLLC, by J. David Stradley and Ann C. Ochsner, and Henson Fuerst, P.A., by Thomas Henson, Jr., for plaintiff-appellee.

DILLON, Chief Judge.

This case arises from a tragic two-vehicle accident resulting in the fatality of

the driver of one of the vehicles. At the conclusion of the trial, the estate of the

deceased victim was awarded $40 million in compensatory and punitive damages

from two defendants: the intoxicated driver of the other vehicle and the owner of that

other vehicle. After careful review, we conclude the trial was free from reversible

error and affirm the trial court’s rulings on Defendants’ post-trial motions. CHAPPELL V. WEBB

Opinion of the Court

I. Background

On the evening of 18 September 2020, Defendant Shemaro Deann Webb was

driving a Nissan Altima southbound on US Highway 401 toward Raleigh while under

the influence of alcohol. Defendant LaDorothy Breanna Foreman was a passenger

and owned the Nissan Altima.

On the same highway, Susan Renee Chappell was driving northbound.

At some point, Defendant Webb crossed the center line of the highway while

attempting to pass another southbound vehicle in a no-passing zone. Her vehicle

collided head-on with Ms. Chappell’s vehicle in the northbound lane. Ms. Chappell

died later that night due to injuries sustained in the accident.

Plaintiff Sandra Chappell, as the administrator of Ms. Chapell’s estate,

brought a wrongful death suit against Defendants, seeking to recover damages

pursuant to North Carolina’s wrongful death statutes. Plaintiff alleged that

Defendant Webb was negligent in driving the vehicle and that Defendant Foreman

was negligent by entrusting Defendant Webb with her vehicle.

At the conclusion of the trial, the jury returned verdicts against Defendants.

The jury found Defendants jointly and severally liable for $15 million in

compensatory damages. The jury found the driver Defendant Webb liable for $5

million in punitive damages and the vehicle owner Defendant Foreman liable for $20

million in punitive damages. The trial court entered a judgment consistent with the

verdicts. Defendants moved for post-trial relief from the judgment. Defendant

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Foreman separately moved for a judgment notwithstanding the verdict (“JNOV”).

The trial court denied both motions. Defendants appeal.

II. Analysis

On appeal, Defendant Foreman argues that the trial court erred in denying

her motion for JNOV. And both Defendants argue that the trial court erred in

denying their other post-trial motions for relief from the large jury verdicts. We

address each argument in turn.

A. Negligent Entrustment Claim & Motion for JNOV

We first address the vehicle owner Defendant Foreman’s argument that she

was entitled to JNOV. She contends Plaintiff did not present sufficient evidence to

prove negligent entrustment. Alternatively, she contends that, even if there was

sufficient evidence to show she was liable for negligent entrustment, there was

insufficient evidence warranting an award of punitive damages against her.

Whether a party is entitled to a motion for JNOV is a question of law, which

we review de novo. Est. of Savino v. Charlotte-Mecklenburg Hosp. Auth., 375 N.C.

288, 293, 847 S.E.2d 677, 681 (2020). As our Supreme Court has instructed:

In making its determination of whether to grant the motion, the trial court must examine all of the evidence in a light most favorable to the nonmoving party, and the nonmoving party must be given the benefit of all reasonable inferences that may be drawn from that evidence. If, after undertaking such an analysis of the evidence, the trial judge finds that there is evidence to support each element of the nonmoving party’s cause of action, then the motion for [JNOV] should be denied.

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Abels v. Renfro Corp., 335 N.C. 209, 214–15, 436 S.E.2d 822, 825 (1993) (internal

marks omitted).

Here, Defendant Foreman contends Plaintiff failed to prove her negligent

entrustment claim. Our Supreme Court has explained that to prove negligent

entrustment, the plaintiff must show two things, namely that (1) the defendant car

owner entrusted her car to another and (2) the car owner knew or reasonably should

have known the other person was in a condition where she was likely to cause injury

to others in her driving:

Negligent entrustment is established when the owner of an automobile entrusts its operation to a person whom he knows, or by the exercise of due care should have known, to be an incompetent or reckless driver, who is likely to cause injury to others in its use. Based on his own negligence, the owner is liable for any resulting injury or damage proximately caused by the borrower’s negligence.

Tart v. Martin, 353 N.C. 252, 254, 540 S.E.2d 332, 334 (2000) (internal citations and

marks omitted). The entrustment element “requires consent from the defendant,

either express or implied, for the third party to use the instrumentality in question.”

Bridges v. Parrish, 222 N.C. App. 320, 327, 731 S.E.2d 262, 267 (2012) (emphasis

added), aff’d, 366 N.C. 539, 540, 742 S.E.2d 794, 796 (2013).

Regarding the entrustment element, Defendant Foreman suggests that

Plaintiff must show more than that Defendant Foreman simply consented to allowing

Defendant Webb to drive her car: Plaintiff must show that Defendant Foreman

voluntarily delivered possession of her vehicle to Defendant Webb. Defendant

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Foreman cites to North Carolina Pattern Jury Instruction 102.68, which the trial

court gave to the jury and which includes a requirement that the jury find that a

negligent entruster “voluntarily gave possession” of her motor vehicle to the driver.1

Our Supreme Court’s jurisprudence, however, does not suggest that there is a

heightened burden beyond that the owner consented, either expressed or implied, to

allowing one she knew or should have known to be incompetent/reckless to drive her

car. See Bridges, 222 N.C. App. at 327, 731 S.E.2d at 267 (holding that a plaintiff

show the defendant-owner gave express or implied consent); Swicegood v. Cooper, 341

N.C. 178, 179, 459 S.E.2d 206, 206 (1995) (holding that the entrustment element is

met where it is shown the owner “had given [the driver] permission to drive the

automobile”). See also State v. Warren, 348 N.C. 80, 119,

Related

State Farm Mutual Automobile Insurance v. Campbell
538 U.S. 408 (Supreme Court, 2003)
Swicegood v. Cooper
459 S.E.2d 206 (Supreme Court of North Carolina, 1995)
DiDonato v. Wortman
358 S.E.2d 489 (Supreme Court of North Carolina, 1987)
Abels v. Renfro Corp.
436 S.E.2d 822 (Supreme Court of North Carolina, 1993)
Boyd v. LG DeWitt Trucking Co., Inc.
405 S.E.2d 914 (Court of Appeals of North Carolina, 1991)
State v. Gladden
340 S.E.2d 673 (Supreme Court of North Carolina, 1986)
Champion v. Waller
150 S.E.2d 783 (Supreme Court of North Carolina, 1966)
State v. Warren
499 S.E.2d 431 (Supreme Court of North Carolina, 1998)
Tart v. Martin
540 S.E.2d 332 (Supreme Court of North Carolina, 2000)
Worthington v. Bynum
290 S.E.2d 599 (Supreme Court of North Carolina, 1982)
Everhart v. O'CHARLEY'S INC.
683 S.E.2d 728 (Court of Appeals of North Carolina, 2009)
Brown v. Moore
213 S.E.2d 342 (Supreme Court of North Carolina, 1975)
Bridges v. Parrish
742 S.E.2d 794 (Supreme Court of North Carolina, 2013)
Haarhuis v. Cheek
805 S.E.2d 720 (Court of Appeals of North Carolina, 2017)
State v. Huey
804 S.E.2d 464 (Supreme Court of North Carolina, 2017)
Justus v. Rosner
821 S.E.2d 765 (Supreme Court of North Carolina, 2018)
Ann Finch v. Covil Corporation
972 F.3d 507 (Fourth Circuit, 2020)
Fredric Eshelman v. Puma Biotechnology, Inc.
2 F.4th 276 (Fourth Circuit, 2021)
Bridges v. Parrish
731 S.E.2d 262 (Court of Appeals of North Carolina, 2012)

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