Patterson v. Cushman

394 P.2d 657, 6 A.L.R. 3d 421, 1964 Alas. LEXIS 227
CourtAlaska Supreme Court
DecidedAugust 3, 1964
Docket360
StatusPublished
Cited by23 cases

This text of 394 P.2d 657 (Patterson v. Cushman) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patterson v. Cushman, 394 P.2d 657, 6 A.L.R. 3d 421, 1964 Alas. LEXIS 227 (Ala. 1964).

Opinion

AREND, Justice.

The plaintiff, Wilbern B. Patterson, brought this action as next friend on behalf of his minor son for injuries sustained by the latter as a consequence of the alleged negligent operation by the defendant, Helen Cushman, of an automobile maintained as a family car by herself and her husband, the other defendant. From a verdict and judgment of nonliability in favor of the defendants, the plaintiff prosecutes this appeal. Pertinent facts will be raised as they may be required for an. understanding of each issue as it is being discussed in this opinion.

The first issue raised by the plaintiff concerns the trial court’s refusal to strike the defendants’ affirmative defense of contributory negligence and its subsequent treatment of the question of contributory negligence by children in its instructions to the jury. These instructions were quite lengthy and it would serve no useful purpose to set *659 them forth verbatim in this opinion. In essence they informed the jury that neither negligence 1 nor contributory negligence were ever presumed; that in order to prevail upon their defense of contributory negligence the defendants would have to prove the same by a preponderance of the evidence ; and that any evidence of negligence on the part of the injured child proximately contributing to the accident and the resulting injuries would bar recovery by him.

The plaintiff complains that the instructions laid so much stress upon contributory negligence that the minor was deprived of a fair trial; and he contends that the court should have stricken the defense of contributory negligence, or at least have instructed.the jury, as requested by him, that a child under seven years of age cannot as a matter of law be guilty of negligence or contributory negligence. In other words, he is saying that Alaska should adopt what has become known as the Illinois rule, or the rule of conclusive presumption, that

“[A] child under seven years of age is incapable of such conduct as will constitute contributory negligence, and the court may so declare as a matter of law * * 2

The reason behind the rule seems to be that “a child under 7 years of age lacks the discretion, judgment- and mental capacity to discern and appreciate circumstances of danger that threaten its safety.” 3

Arrayed against the proponents of the "Illinois Rule” are those jurisdictions which have rejected the claim that some arbitrary age, such as four, five, six or seven, should be set below which a child must be conclusively presumed to be incapable of contributory negligence. 4 They recognize the presumption of incapacity but regard it as one which is rebuttable. Common sense is on their side for it dictates that there aré other factors besides a child’s age, e. g., judgment and experience, which must bp considered in order to properly determine the child’s capacity for contributory negligence. As stated by Judge Jayne in Hellstern v. Smelowitz: 5

“It seems entirely reasonable to su'pr pose that the capacity of an infant to understand and to avoid dangers to which it is exposed in a given set of circumstances does not depend so much upon the chronological age of the infant as upon the infant’s psychological development.”
“The ripening of the mental faculties of children in general must, we think, have been accelerated by the progressive enlargement of a child’s scope of observations and experiences in our modern environment.”
“Under the so-called Illinois rule a boy who is one day under seven years of age may be guilty of the most flagrant contributory carelessness and yet evidence of his exceptional precocity and breadth of judgment and experience cannot be introduced to over *660 come the illusory presumption of baby like puerility.” 6

We reject the Illinois rule of conclusive presumption and adopt for Alaska the view that a child of less than seven years of age is rebuttably presumed to be incapable of contributory negligence. As to such a child there are two issues to be decided: (1) Whether the child has the capacity to be contributorily negligent, and (2)whether he was in fact contributorily negligent. These issues might well both be jury questions unless fair minded men in the exercise of reasonable judgment could not differ on the inferences to be drawn from the evidence. 7

With respect to the first issue mentioned in the preceding paragraph, the evidence in the instant case was such as- to leave no doubt in a reasonable mind that the child was capable of some degree of care and of taking some precautions for. his own safety. He knew the danger from automobiles and had been warned by his parents to watch out for vehicles and not to play in the streets. Under these circumstances the trial court would have had to rule as a matter of law that the child was capable of contributory negligence, 8 leaving for the jury only the issue of whether he was in fact contributorily negligent.

The trial court properly defined ordinary care as applicable to the child in this case by instructing the jury that

“A child is guilty of contributory negligence when he docs something which an ordinary child of like age, intelligence, and experience would not do under the circumstances and conditions of a given case, or when he fails to take such precautions for his own safety as an ordinarily prudent child of like age, intelligence, and experience would take under the same circumstances and conditions. * * * ”

During the course of the trial the plaintiff called as a witness one Donald Redman who testified that immediately preceding the accident he saw the child playing — “walking with one foot on the sidewalk or curb and one down off the curb into the street” — and then stumbling out into the street and falling into or coming into contact with the right front fender of the defendant’s car. Redman was then shown an unsworn written statement made by him one week after the accident to Air Force Police officers investigating the accident 9 from which the following portion was read into the record:

' “I saw Mrs. Cushmans [jic] [defendant’s] car driving less than three feet from the curb where this little boy was walking ‘up and down’. I saw her car strike the child. I do not know whether her right front bumper struck the child, or whether her right front fender struck the child, but I do know that T saw the right front corner of the car strike the boy * *

.The witness readily admitted making the statement and explained that in it he had failed to say how the boy got off the curb. On cross examination he identified an earlier written statement, given by him to the Air Force Police only one day after the accident, in which he related:

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Bluebook (online)
394 P.2d 657, 6 A.L.R. 3d 421, 1964 Alas. LEXIS 227, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patterson-v-cushman-alaska-1964.