Kunkel v. Alger

406 N.E.2d 402, 10 Mass. App. Ct. 76, 1980 Mass. App. LEXIS 1202
CourtMassachusetts Appeals Court
DecidedJune 23, 1980
StatusPublished
Cited by28 cases

This text of 406 N.E.2d 402 (Kunkel v. Alger) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kunkel v. Alger, 406 N.E.2d 402, 10 Mass. App. Ct. 76, 1980 Mass. App. LEXIS 1202 (Mass. Ct. App. 1980).

Opinion

Greaney, J.

On December 4, 1971, in Acton, Maine, the plaintiff suffered a fractured leg while riding as a passenger on a snowmobile operated by the defendant Theodore Lebida and owned by the defendant Francis N. Alger. His action in the Superior Court originally sought recovery *77 against Lebida for negligent operation of the snowmobile and against Alger on the basis of vicarious liability. The case was tried to a jury (under the substantive law of the State of Maine) against Lebida on the theory expressed above, and against Alger on the theory that he negligently entrusted the snowmobile to an inexperienced person. The defendants’ motions for directed verdicts (Mass.R.Civ.P. 50[a], 365 Mass. 814 [1974]), made at the close of the plaintiff’s case and again at the close of all the evidence, were denied. The jury returned verdicts for Lebida and against Alger, assessing damages against Alger in the amount of $100,000. Alger moved for judgment notwithstanding the verdict (Mass.R.Civ.P. 50[b], 365 Mass. 814 [1974]), and, alternatively, sought a new trial. Kunkel moved for a new trial as to Lebida. 2 That portion of Alger’s motion seeking judgment n.o.v. was denied; that part of his motion requesting a new trial was allowed only as to damages, unless the plaintiff should accept a remittitur of $25,000. At the same time, the plaintiff’s motion to amend his complaint “to conform [it] to the evidence” (Mass.R.Civ.P. 15[b], 365 Mass. 761-762 [1974]), by adding an express claim against Alger for negligent entrustment, was allowed, 3 and the motion for new trial as to Lebida was denied. When the plaintiff accepted the remittitur, an amended judgment setting damages at $75,000 was entered. The plaintiff has not appealed from the judgment in favor of Lebida or from the denial of his motion for new trial. Alger has appealed from the denial of his motions seeking posttrial relief and from the amended judgment. We hold that the judgment in Alger’s case must be reversed, the verdict set aside and a *78 new trial ordered. 4 Questions as to the status of the case against Lebida are left for consideration in the Superior Court.

The following is a summary of the relevant evidence and other material events at the trial. The plaintiff, along with others, had been performing work at Alger’s residence in Acton, Maine, on December 4, 1971. There were about ten or twelve inches of new snow on the ground. The workers had left their automobiles parked on a road about one mile distant from the residence. Throughout the course of the day, passengers and supplies were transported to and from the house by snowmobile and sled along a camp road which led from the parking area to the residence. Alger’s neighbor, one Doherty, an experienced snowmobile operator, had established a clear path of tamped snow about four and one-half feet wide over the length of the road.

By dusk the workers were preparing to return to their cars. Kunkel arranged to ride as a passenger on Alger’s snowmobile, which was operated by Lebida. Lebida’s familiarity with the snowmobile consisted of operating it *79 that day for approximately forty-five minutes, after having received instructions from Doherty, and on a previous occasion from another experienced driver. Tools were loaded on the sled behind the vehicle, and Alger’s son, then age twelve, prepared to ride on the back of the sled. Kunkel was provided with a helmet and, according to their testimony, was instructed by Messrs. Alger, Lebida and Doherty to tuck in loose clothing, to lean in the same direction as the operator when traveling over contoured terrain, and to keep his feet within the stirrups provided on the machine for the protection of the passenger’s feet. Kunkel did not recall receiving these instructions. Kunkel testified that he kept his feet inside the snowmobile, that after the machine reached the top of a steep hill “it just went sideways, out of control. . . [and] something hit my leg . . . tak[ing my] leg out of the stirrup .... [T]he next thing I know, I was in the snowbank.” Alger testified that he observed Kunkel removing his right foot from the stirrup and that he shouted at him to keep his foot in but could not be heard over the noise of the snowmobile engine. Alger’s son testified that from his position on the sled behind the snowmobile, he also observed Kunkel’s foot out of the stirrup just prior to the accident. He testified that the path “slanted to the right,” that the snowmobile “slid” or “leaned” to the right, that he heard Lebida yell to Kunkel to lean (to the left), that Kunkel did not lean, that the machine tipped, and that Kunkel, who had his right foot out of the stirrup, caught it in the snow as the machine was tipping. He testified that after the accident the sled, which moved independently of the snowmobile, was in the center of the path. He saw no ruts in the path. Lebida testified that as the vehicle “started up the second hill... I could feel the machine or the weight shift, so I yelled to lean and I leaned and ... I felt resistance, so I let off the throttle . . . [and] [t]he snowmobile stopped ... in the middle of the path . . . lying against the embankment on the right-hand side . . . [but did not] hit the enbankment.”

A game warden of the State of Maine, Vernon Walker, investigated the accident. His deposition read at the trial *80 indicated that he had completed a snowmobile accident report. That report stated, as to the cause of the accident, that the machine was “ [travelling on rutted road at moderate speed, sled went into old wheel rut, passenger’s leg caught between sled and frozen banking. [0]perator never drove a snow sled before.” Walker also stated in the deposition that, although he had made the foregoing entry, based on his investigation, “[njobody was to blame, [it] was just an accident, [and he] did not mean to indicate by this entry that [inexperience] was a cause of the accident [because] I don’t know what caused the accident.” The remainder of the evidence is not relevant to our disposition of the issues.

In his summation, the plaintiff’s counsel argued to the jury: “Ladies and gentlemen, as to the liability in this matter, I’m going to ask you to find that both defendants in this case were negligent. That Ted Lebida was negligent in the operation of that vehicle, by reason of his inexperience. I’m also going to ask you to find that Frank Alger was negligent in entrusting this dangerous instrumentality, and making provisions for the transportation of Henry Kunkel, out of there by such an inexperienced person. That he certainly did not have the experience or the knowledge to instruct anybody with respect to anything concerning the operation or being a passenger on such a motor vehicle.” Defense counsel in his closing argued to the jury that Lebida was not negligent in operating the snowmobile and that the accident was caused solely by Kunkel’s having his right foot outside of the stirrup in a position where it could, and did, encounter an obstacle in the path. He did not discuss the connection between Lebida’s conduct and Alger’s potential responsibility. Both parties submitted requests for instructions which framed liability in terms of whether the defendants’ conduct subjected the plaintiff to an unreasonable risk of harm.

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Bluebook (online)
406 N.E.2d 402, 10 Mass. App. Ct. 76, 1980 Mass. App. LEXIS 1202, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kunkel-v-alger-massappct-1980.