Leigh Smithwick v. Ross Campbell

CourtCourt of Appeals of Georgia
DecidedOctober 18, 2021
DocketA21A0733
StatusPublished

This text of Leigh Smithwick v. Ross Campbell (Leigh Smithwick v. Ross Campbell) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Leigh Smithwick v. Ross Campbell, (Ga. Ct. App. 2021).

Opinion

SECOND DIVISION MILLER, P. J., HODGES and PIPKIN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

October 18, 2021

In the Court of Appeals of Georgia A21A0733. SMITHWICK v. CAMPBELL.

MILLER, Presiding Judge.

In this tort case involving a rear-end collision, the jury found in favor of the

defendant, Ross Campbell. The plaintiff, Leigh Smithwick, appeals from the trial

court’s denial of her motion for new trial and motion for judgment notwithstanding

the verdict, arguing that the defense of sudden emergency was not supported by the

evidence. Because a careful review of the record reveals at least some evidence

authorizing the sudden emergency instruction, the trial court properly charged the

jury on this defense. Accordingly, we affirm.

“On appeal, the evidence is construed most strongly to support the verdict and

judgment.” (Citation omitted.) Smith v. Norfolk Southern R. Co., 337 Ga. App. 604,

605 (788 SE2d 508) (2016). So construed, the evidence shows that on a morning in September 2013, while

traveling on Interstate 575, Smithwick and Campbell proceeded onto Exit 8 into

extremely heavy, “stop-and-go traffic.” “It wasn’t quite light out[,]” and the roadway

was wet from light rain. Campbell traveled approximately one car-length behind

Smithwick’s vehicle, and both Campbell and Smithwick drove very slowly while

“lining up” in preparation to make a right turn. An unknown driver then traveled from

the highway and cut in front of Smithwick, which caused Smithwick to swerve

slightly in the lane and slam on her brakes. Campbell began slowing down after he

saw other cars doing the same, but he rear-ended Smithwick.1 Campbell testified that

“maybe two seconds” passed between the time that the unknown driver came onto the

exit and the point at which the other drivers reacted. He further explained that “a

domino effect” resulted after the unknown driver cut in front of Smithwick.

Campbell’s vehicle was not damaged, but Smithwick’s vehicle sustained damage to

the bumper, taillight, and trunk. Smithwick described the collision as “slight,” but she

began experiencing neck pain approximately a week after the accident.

1 It appears from the record that the investigating officer did not issue a ticket to Campbell.

2 In 2015, Smithwick filed a negligence lawsuit against Campbell, seeking

recovery for medical expenses and pain and suffering. Campbell denied liability,

partly on the basis that a sudden emergency arose when the unknown driver cut in

front of Smithwick’s vehicle, which caused her to make a sudden stop. After the close

of evidence at trial, Smithwick moved for a directed verdict on the sudden emergency

defense, which the trial court denied. During the charge conference, Smithwick

argued that Campbell could not avail himself of the sudden emergency defense

because he had testified to having followed too closely behind her. Over Smithwick’s

objection, the trial court charged the jury on the sudden emergency doctrine as

follows:

Members of the jury, one who is confronted with a sudden emergency that was not caused by one’s own fault and is without sufficient time to determine accurately and with certainty the best thing to be done is not held to the same accuracy of judgment as would be required of that person if he had more time for deliberation. The requirement is that the person act with ordinary care under all particular facts and circumstances surrounding the situation, including, but not limited to obeying the traffic laws of this [S]tate. The trial court also instructed the

3 jury on the statutory duty regarding following too closely, as embodied in OCGA 40-6-49 (a).2

The jury returned a defense verdict in favor of Campbell. Smithwick filed a

motion for new trial and a motion for judgment notwithstanding the verdict,

challenging the trial court’s decision to give the sudden emergency instruction. After

a hearing, the trial court denied both motions. The court reasoned that the sudden

emergency charge was proper because (1) the unknown driver suddenly and

unexpectedly darted in front of Smithwick; (2) the question of whether Campbell had

been following Smithwick too closely was for the jury’s consideration; and (3)

Campbell faced a choice of conduct immediately preceding the accident. Smithwick

filed this timely appeal.

2 This instruction was as follows:

The driver of a motor vehicle shall not follow another vehicle more closely than is reasonable and prudent, having due regard for the speed of such vehicles and the traffic upon and the condition of the highway. If you find that the defendant violated that provision, then that would be negligence as a matter of law.

4 1. As an initial matter, we address Campbell’s claim that we are precluded from

considering this appeal. Campbell contends that (1) the trial court’s denial of

Smithwick’s motion for judgment notwithstanding the verdict remains the law of the

case because Smithwick has not challenged that ruling in her enumeration of errors;

and (2) Smithwick failed to preserve her challenge to the jury instruction based on the

second element of the sudden emergency defense, i.e., that Campbell was not

presented with a choice of conduct after the emergency situation arose. Both of these

claims lack merit.

[W]here it is apparent from the notice of appeal, the record, the enumeration of errors, or any combination of the foregoing, what judgment or judgments were appealed from or what errors are sought to be asserted upon appeal, the appeal shall be considered in accordance therewith notwithstanding that the notice of appeal fails to specify definitely the judgment appealed from or that the enumeration of errors fails to enumerate clearly the errors sought to be reviewed.

(Citation omitted.) Mateen v. Dicus, 281 Ga. 455, 456 (637 SE2d 377) (2006). In her

notice of appeal, Smithwick specifically indicates that she is appealing from both the

denial of her motion for new trial and the trial court’s denial of her motion for

judgment notwithstanding the verdict. Additionally, the arguments contained in

Smithwick’s enumeration of errors are the same arguments that she raised in her

5 motion for judgment notwithstanding the verdict and in her motion for new trial.

Because we can clearly discern the two judgments from which Smithwick is

appealing, both judgments are properly before the Court.

Additionally, Smithwick preserved the two evidentiary grounds underlying her

objection to the jury instruction. In civil cases, “no party may complain of the giving

[of] . . . an instruction to the jury unless he objects thereto before the jury returns its

verdict, stating distinctly the matter to which he objects and the grounds of his

objection.” OCGA § 5-5-24 (a). Compliance with this statute “is all the law requires

to preserve an objection for appeal.” Pearson v. Tippmann Pneumatics, Inc., 281 Ga.

740, 743 (2) (642 SE2d 691) (2007).

At the charge conference, Smithwick plainly argued to the trial court that the

sudden emergency instruction was inapplicable because (1) Campbell participated in

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Flanigan v. Reville
130 S.E.2d 258 (Court of Appeals of Georgia, 1963)
Converse v. O'KEEFE
252 S.E.2d 92 (Court of Appeals of Georgia, 1979)
Cartey v. Smith
125 S.E.2d 723 (Court of Appeals of Georgia, 1962)
Lucas v. Love
519 S.E.2d 253 (Court of Appeals of Georgia, 1999)
Stephens v. Hypes
610 S.E.2d 631 (Court of Appeals of Georgia, 2005)
Prophecy Corp. v. Charles Rossignol, Inc.
343 S.E.2d 680 (Supreme Court of Georgia, 1986)
Willis v. Love
502 S.E.2d 487 (Court of Appeals of Georgia, 1998)
Metropolitan Atlanta Rapid Transit Authority v. Mehretab
480 S.E.2d 310 (Court of Appeals of Georgia, 1997)
Cornelius v. Hutto
558 S.E.2d 36 (Court of Appeals of Georgia, 2001)
Butgereit v. Enviro-Tech Environmental Services, Inc.
586 S.E.2d 430 (Court of Appeals of Georgia, 2003)
Malcom v. Malcolm
144 S.E.2d 188 (Court of Appeals of Georgia, 1965)
Dubberly v. Cooper
573 S.E.2d 442 (Court of Appeals of Georgia, 2002)
Mateen v. Dicus
637 S.E.2d 377 (Supreme Court of Georgia, 2006)
MAXINEAU v. King
695 S.E.2d 732 (Court of Appeals of Georgia, 2010)
Pearson v. Tippmann Pneumatics, Inc.
642 S.E.2d 691 (Supreme Court of Georgia, 2007)
SMITH Et Al. v. NORFOLK SOUTHERN RAILWAY COMPANY
788 S.E.2d 508 (Court of Appeals of Georgia, 2016)
McDowell v. Hartzog
736 S.E.2d 395 (Supreme Court of Georgia, 2013)
Robert, Ltd. v. Parker
450 S.E.2d 219 (Court of Appeals of Georgia, 1994)
Beckett v. Monroe
548 S.E.2d 131 (Court of Appeals of Georgia, 2001)
Cameron v. Peterson
589 S.E.2d 834 (Court of Appeals of Georgia, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
Leigh Smithwick v. Ross Campbell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leigh-smithwick-v-ross-campbell-gactapp-2021.