Estate of Emily Snow v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways

CourtCourt of Appeals of Kentucky
DecidedOctober 6, 2022
Docket2021 CA 001409
StatusUnknown

This text of Estate of Emily Snow v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways (Estate of Emily Snow v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Emily Snow v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways, (Ky. Ct. App. 2022).

Opinion

RENDERED: OCTOBER 7, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2021-CA-1409-MR

ESTATE OF EMILY SNOW APPELLANT

APPEAL FROM BOYLE CIRCUIT COURT v. HONORABLE DARREN W. PECKLER, JUDGE ACTION NO. 21-CI-00191

COMMONWEALTH OF KENTUCKY, TRANSPORTATION CABINET, DEPARTMENT OF HIGHWAYS AND KENTUCKY BOARD OF CLAIMS F/K/A KENTUCKY CLAIMS COMMISSION APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, MCNEILL, AND K. THOMPSON, JUDGES.

COMBS, JUDGE: The Estate of Emily Snow appeals from a judgment of the

Boyle Circuit Court affirming a decision of the Kentucky Board of Claims in favor

of Commonwealth of Kentucky Transportation Cabinet, Department of Highways.

After our review, we affirm. In the late night hours of June 29, 2014, 16-year-old Emily Snow was

killed in a one-car accident on KY 1856 in rural Boyle County. She was riding

without a seatbelt in the back seat when the car neared the end of a curve, crossed

the oncoming traffic lane, left the wet road, and struck a tree. Jacob Smith, the 18-

year-old driver, admitted to a deputy sheriff at the scene that he had been drinking

beer and that he was travelling too fast to negotiate the turn. The speed limit was

not posted, but the regulatory limit is 55 miles per hour. Signage consisted of a

single reflective chevron, mid-curve.

On June 29, 2015, the co-administrators of Snow’s estate (the Estate)

filed a wrongful death action with the Board of Claims against the Transportation

Cabinet. They alleged that Snow’s death was caused by the failure of the

Transportation Cabinet to post adequate signage to warn drivers of the “curvature

and grade of the road.” The Transportation Cabinet denied negligence and asserted

its immunity as a defense.

On February 13, 2019, an administrative hearing was conducted in

Boyle County. The parties presented testimony from various experts and lay

witnesses. For the Estate, Jerry Pigman, an engineer and crash reconstructionist,

testified (by deposition) that based upon his analysis, the curve would be

challenging to navigate at a speed in excess of 25 to 30 miles per hour. Because

the speed limit along the road was 55 miles per hour, Pigman felt that a right turn

-2- sign posted ahead of the curve was the minimum signage that he would have

recommended. He indicated that two additional chevron signs erected along the

curve would have guided drivers safely through it. Pigman acknowledged that

multiple passengers in a car generally proved distracting to teen drivers; that the

driver’s ability to drive safely was impacted by his consumption of alcohol; and

that the failure to engage seatbelts resulted in more severe injuries to passengers.

On cross-examination, Pigman admitted that relevant provisions of the

Manual of Uniform Traffic Control Devices (MUTCD), with which he was very

familiar, did not require the signage he recommended; instead, that manual

directed that an engineer (or one at his direction) could use his own judgment and

discretion with respect to traffic control devices placed on lightly travelled roads

like KY 1856. He specifically agreed that civil engineers (and those at their

direction) were expected to use their judgment and discretion when making

decisions regarding signage on a road scarcely travelled, adding, “I think that

engineering judgment is essentially discretionary decision making. . . .” Moreover,

he acknowledged that an engineer was authorized by the provisions of the

MUTCD to consider the crash history of a roadway before arriving at a decision

with respect to signage. He acknowledged that he had not considered this factor

before arriving at his opinion.

-3- Henry Cease, Jr., an accident reconstructionist, testified that the curve

should have been marked with a curve warning sign indicating a recommended

speed of 25 miles per hour along with multiple chevron signs in the curve. On

cross-examination, he acknowledged that he had no experience implementing or

interpreting the MUTCD and no expertise in the Transportation Cabinet’s policies,

practices, or procedures. His investigation indicated that the road banked properly

into the curve making it inherently easier to navigate.

The Transportation Cabinet admitted that it was responsible for the

maintenance of KY 1856 -- including signage. However, it denied any negligence

and argued that Snow’s death was caused by the negligence of others -- including

the driver. Moreover, it contended that it was immune from liability for any

negligence in the performance of its discretionary functions, specifically including

decisions regarding road signage on lightly travelled roadways.

Deputy Sheriff Phillip Dean testified that he responded to the crash

and investigated the incident. He indicated that KY 1856 was not known for traffic

accidents and confirmed that it was a rural roadway that was only lightly travelled.

Jeffrey Sparks, an engineering technologist with the Transportation

Cabinet, testified that KY 1856 was inspected for safety by the Boyle County

Maintenance Garage at least once per month. He indicated that foliage had been

trimmed from the sides of the roadway approximately one month before the fatal

-4- collision. He did not know when, why, or by whom the reflective chevron sign

had been posted at the curve.

Kenneth Robert Agent, a civil engineer, instructor, and researcher

employed by the University of Kentucky College of Engineering, testified that he

taught engineers and other transportation professionals various subjects related to

placement of traffic control devices and highway safety. Agent described KY

1856 as a “relatively narrow, very curvy road, very, very low average daily traffic.

. . .” He observed that the road was relatively flat at the site of the collision and

that given the “long tangent leading to the curve,” a driver could easily see it from

at least 200 feet with low beam headlights illuminated. He indicated that the sight

line was enhanced by the existence of a double centerline pavement marking that

would give a driver “delineation that [he is] going into a right-hand curve.”

Agent explained that the exercise of engineering judgment would not

indicate that the curve at the site of the collision required signage for several

reasons. First, the change in roadway alignment did not “violate [the driver’s]

expectancy” because “the road is just one curve after another.” Next, he noted that

a lack of any serious accident history or complaints about the safety of the road

would weigh in favor of a decision not to erect signage. Additionally, he observed

that the rural road was only very lightly travelled. In Agent’s opinion, “there was

[sic] plenty of visual ques [sic] to drive through the curve fine at that location

-5- without any signs.” Reviewing specific provisions of the MUTCD, Agent testified

that under these circumstances, decisions with respect to traffic control devices

placed at this location were absolutely a matter of discretion. He indicated that he

had been unable to determine when or how the single reflective chevron had come

to be placed in the curve.

Based upon the evidence presented, the hearing officer found that the

curve where the car left the roadway could be safely negotiated at a speed of

approximately 20 to 25 miles per hour.

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