Geschwind v. Flanagan

854 P.2d 1061, 121 Wash. 2d 833, 1993 Wash. LEXIS 154
CourtWashington Supreme Court
DecidedJuly 15, 1993
Docket59300-1
StatusPublished
Cited by84 cases

This text of 854 P.2d 1061 (Geschwind v. Flanagan) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Geschwind v. Flanagan, 854 P.2d 1061, 121 Wash. 2d 833, 1993 Wash. LEXIS 154 (Wash. 1993).

Opinions

Durham, J.

On the evening of Friday, October 26,1984, Timothy Geschwind was a passenger in a truck driven by Timothy Flanagan. At approximately 12:55 a.m. on the morning of October 27, Flanagan drove his truck off the road, killing himself and injuring Geschwind. Both men were significantly intoxicated. In a subsequent action brought by Geschwind to recover damages for his injuries, a jury found him to be 70 percent at fault for his own injuries. Pursuant to RCW 5.40.060, which prohibits recovery by an intoxicated plaintiff if the intoxication was a proximate cause of the injuries and the plaintiff is more than 50 percent at fault, Geschwind was denied recovery, and the defendant was awarded judgment. We are asked to answer two distinct questions: (1) can a negligent passenger ever be more at fault for his or her injuries than a negligent driver? and (2) does RCW 5.40.060 prohibit recovery to an intoxicated passenger when the intoxication was a proximate cause of his or her injuries, and the passenger is found to be more than 50 percent at fault for those injuries? We answer both questions in the affirmative.

The facts of this case follow a pattern which, despite the best efforts of the citizens, courts and Legislature of this state, remains all too commonplace. On the evening in question, Geschwind and Flanagan planned to "go out and party, and . . . get a little buzzed." Report of Proceedings (RP) vol. 5, at 15. With Flanagan driving, they drank a number of beers while on Whidbey Island, and then caught the 8:30 p.m. ferry to Everett. After arriving in Everett, they stopped in one tavern where they had another beer or two, then continued on to a bar, where Geschwind had at least two potent mixed drinks. They ended their drinking at a third bar, where Geschwind recalléd having a beer and a shot. Although Geschwind was not monitoring Flanagan's alcohol intake, he believed that Flanagan was drinking about the same amount.

[836]*836While pulling out of his parking space at the last bar, Flanagan bumped the cars in front of him and behind him. Geschwind then asked his friend if he (Geschwind) should drive, but Flanagan declined the offer. Geschwind believed Flanagan's driving was passable once Flanagan was on the main road, and Geschwind dozed off in the passenger seat. Subsequently, Flanagan drove off the road and crashed into a telephone pole. Flanagan's blood alcohol content (BAC) at the time of the accident was .38; Geschwind's BAC was .17.1

At trial, Geschwind admitted that both of them planned to "get buzzed." RP vol. 5, at 14-15. Geschwind defined being "buzzed" as any point before being falling-down drunk. He also testified that he considered it safe to drive with "somebody who's got a buzz on, so long as they're not falling down drunk[.]" RP vol. 5, at 16. Geschwind admitted that although he thought that Flanagan was "over-buzzed", he voluntarily chose to stay in the truck rather than get out in an area that he did not know.

The trial judge instructed the jury on the issue of contributory negligence as follows:

If you find that the plaintiff was the passenger and that he voluntarily rode in the truck after he knew, or in the exercise of ordinary care should have known, the driver's condition, and if you also find that a person using ordinary care would not have ridden in the truck, and if you further find that the driver's condition was a proximate cause of plaintiff's injury or damages, you will find plaintiff contributorily negligent.

Defendant's Clerk's Papers (DCP), at 22. The jury was also instructed as to the effect of RCW 5.40.060, which prohibits recovery if the plaintiff was intoxicated, the intoxication was a proximate cause of the injuries, and the plaintiff was more than 50 percent at fault. The jury returned an answer in a special verdict form2 which attributed 70 percent of the fault [837]*837for his injuries to Geschwind himself. The jury also found that Geschwind's intoxication was a proximate cause of his injury. Pursuant to RCW 5.40.060, judgment was entered for the defendant.

On appeal, the Court of Appeals reversed and remanded for a new trial. Accepting Geschwind's argument that a passenger cannot legally be responsible for more than 50 percent of his or her injuries, the court stated that "[wjhile the jury apparently found appellant highly culpable, it should not have been permitted to find him more culpable than the intoxicated driver who had the primary responsibility for reasonably safe operation of the vehicle." Geschwind v. Flanagan, 65 Wn. App. 207, 214, 828 P.2d 603 (1992). This court accepted the petition for review.3

Generally, the issue of contributory negligence is one for the jury. Young v. Caravan Corp., 99 Wn.2d 655, 661, 663 P.2d 834, 672 P.2d 1267 (1983). The jury found Geschwind 70 percent at fault for his own injuries. The Court of Appeals reversed on the theory that a passenger can never, as a matter of law, be liable for more than 50 percent of his or her injuries. This raises an issue of first impression.

In 1981, Washington adopted contributory fault as a method of apportioning damages as between a negligent plaintiff and a negligent defendant. Laws of 1981, ch. 27, § 8, p. 117, codified at RCW 4.22.005. "Fault" is defined as including "unreasonable assumption of risk, and unreasonable failure to avoid an injury.. ,."4 RCW 4.22.015. The determination of the percen[838]*838tage of total fault attributable to each party, "including the claimant or person suffering personal injury", is specifically reserved for the trier of fact. Former RCW 4.22.070.

The courts of this state have long held that a passenger may be found to be contributorily negligent by voluntarily riding in a car with a driver who he or she knows, or reasonably should know, is intoxicated. Traverso v. Pupo, 51 Wn.2d 149, 152-53, 316 P.2d 462 (1957); Morse v. Frank, 1 Wn. App. 871, 873, 466 P.2d 166 (1970). See also WPI 12.01.01 (can find plaintiff contributorily negligent if driver intoxicated, plaintiff knew, or should have known, of driver's condition, person of ordinary care would not have ridden in car, and driver's condition is a proximate cause of plaintiff's injury). Prior to the adoption of the comparative fault statute, a plaintiff's contributory negligence acted as a complete bar to recovery, regardless of the percentage of fault. E.g., Morse, at 873.

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Bluebook (online)
854 P.2d 1061, 121 Wash. 2d 833, 1993 Wash. LEXIS 154, Counsel Stack Legal Research, https://law.counselstack.com/opinion/geschwind-v-flanagan-wash-1993.