Hummel v. King

32 Pa. D. & C.3d 463, 1984 Pa. Dist. & Cnty. Dec. LEXIS 312
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedAugust 24, 1984
Docketno. 81-11775
StatusPublished

This text of 32 Pa. D. & C.3d 463 (Hummel v. King) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Delaware County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hummel v. King, 32 Pa. D. & C.3d 463, 1984 Pa. Dist. & Cnty. Dec. LEXIS 312 (Pa. Super. Ct. 1984).

Opinion

PRESCOTT, A.J.,

The matter presently before this court is a motion for new trial filed by plaintiff.

The sole issue raised by said motion is:

(1) Whether a verdict of “no damages” can be sustained in a comparative negligence case where plaintiff and defendant are found by the jury to be equally at fault and where there is evidence of some injury to plaintiff?

Before addressing the foregoing issue, the factual background of the case is appropriate to discuss.

On September 19, 1980, plaintiff and defendant were involved in an automobile accident which occurred when defendant drove his automobile out of a shopping mall exit and onto a public street without being able to see oncoming traffic and his vehicle collided with plaintiff’s vehicle. Plaintiff stated that the impact caused her knee to hit the doorknob of the window of her car. Plaintiff’s sister, a passenger in plaintiff’s car testified that she heard plaintiff’s leg hit the door during the collision and that plaintiff told her immediately after the impact that her leg was very sore. Plaintiff and various witnesses testified that plaintiff complained of pain after the accident and her activities became restricted.

Plaintiff testified that she has had major problems with her left knee since she was 12 years old and was diagnosed as having rheumatoid arthritis at the age of 14. She further testified that before the accident she had pain in her knee and was restricted in her activities. She had been treated and diagnosed by more than one physician prior to the collision which occurred on September 19, 1980.

Two physicians testified on behalf of plaintiff by way of videotape deposition. A report of a third physician was also introduced in plaintiff’s case. All [465]*465three physicians acknowledged that plaintiff had a problem with her knee prior to the collison but that the accident in question aggravated plaintiff’s prior condition, increased her prior disability and enhanced her pain. David Hoffman, M.D., testified on behalf of defendant and in response to a question as to whether the accident aggravated plaintiff’s condition, he stated: “If you mean by aggravation that her symptoms for some temporary period were heightened by the accident, that seems certain.”

Robert Wolf, Ph.D., a professional vocational rehabilitation specialist and labor market specialist testified on behalf of plaintiff. He stated that plaintiff’s condition would cause her a loss of earnings of $157,783. In giving this estimate he made no distinction between plaintiff’s condition prior to and subsequent to the accident.

At the conclusion of the trial the court gave the following instructions pertaining to comparative negligence and compensation:

“If you find that Plaintiff was contributorily negligent and such negligence was a substantial factor in bringing about her injuries then you must apply the Comparative Negligence Act, which provides as follows, and I quote, “The fact that a Plaintiff may have been guilty of contributory negligence, shall not bar a recovery by the Plaintiff where such negligence was not greater than the causal negligence of the defendant, or Defendants against whom recovery is sought; but any damages sustained by the Plaintiff shall be diminished in proportion to the amount of negligence attributed to the Plaintiff.”
“If you find that the Plaintiff’s causal negligence was equal to or less than the causal negligence of the Defendant, then you must set forth percentages of causal negligence attributable to the Defendant.
[466]*466The total of these percentages must be one hundred percent. You will then determine the total amount of damages for which the Plaintiff would be entitled, if she had not been con tribu torily negligent.”
“If you find that the Defendant is liable to the Plaintiff you must find an amount of money which you believe will fairly and adequately compensate the Plaintiff for the physical injury she has sustained as a result of the accident. The amount which you award must compensate the Plaintiff completely for damage that Plaintiff will sustain in the future.”
“The fact that Plaintiff may have been particularly susceptible to serious injury, will not limit Defendant’s liability where personal injuries caused by the Defendant aggravated an existing deformity or disease resulting in prolongation of the injuries and corresponding increase in damages, compensation for such added increase damages may be recovered.”

The court then presented the jury with a verdict form and read this to the jury as follows:

“Question 1.

Do you find that the defendant was negligent? (yes or no) _

If you answer Question 1 “no”, you should not answer any further questions and should return to the courtroom.

Question 2.

Was the Defendant’s negligence a substantial factor in bringing about Plaintiff’s injuries? (yes or no) _

If you answer Question 2 “no”, you should not answer any further questions and should return to the courtroom.

[467]*467Question 3.

Was the Plaintiff contributoiily negligent? (yes or no) _

If you answer Question 3 “no”, proceed to Question 6.

If you answer Question 3 “yes”, proceed to Question 4.

Question 4.

Was the Plaintiff’s contributory negligence a substantial factor in bringing about Plaintiff’s injuries? (yes or no) _

If you answer Question 4 “no”, proceed to Question 6.

If you answer Question 4 “yes”, proceed to Question 5.

Question 5.

Taking the combined total of negligence in this case which substantially caused the Plaintiff’s injuries as 100 percent, what percentage of that causal negligence was attributable to the Defendant and what percentage was attributable to Plaintiff?

Percentage of causal negligence attributable to Defendant: %

Percentage of causal negligence attributable to Plaintiff: %

TOTAL 100%

If you have found the Plaintiff’s causal negligence to be greater than 50%, you should not answer Question 6 and you should return to the courtroom.

Question 6.

State the amount of damages, if any, sustained by the Plaintiff as a result of the accident, without regard to and without reduction by the percentage of causal negligence, if any, that you have attributed to the Plaintiff.

[468]*468The jury retired for deliberations at 3:30 p.m. and returned with a verdict at 5:24 p.m.

Before the reading of the verdict, the court noticed an irregularity in the verdict form in that Question No. 6 was unanswered. The court then proceeded to question the jury foreman:

The Court: “Mr. Hyde, in examining the verdict slip, which you have just read from, I noted that there were certain crossing out and the one question has your signature beside it. Would you explain for all parties concerned, how it happened that the questionnaire form has been answered in all parts and then crossed out?

The Foreman: Yes, ma’am. We neglected to clearly read the instruction on Question No. 5 where it said Plaintiff’s causal injuries 50-50.

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Cite This Page — Counsel Stack

Bluebook (online)
32 Pa. D. & C.3d 463, 1984 Pa. Dist. & Cnty. Dec. LEXIS 312, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hummel-v-king-pactcompldelawa-1984.