Richard v. Chester Extended Care Center

15 Pa. D. & C.3d 770, 1980 Pa. Dist. & Cnty. Dec. LEXIS 410
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedApril 15, 1980
Docketno. 76-2560
StatusPublished

This text of 15 Pa. D. & C.3d 770 (Richard v. Chester Extended Care Center) 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
Richard v. Chester Extended Care Center, 15 Pa. D. & C.3d 770, 1980 Pa. Dist. & Cnty. Dec. LEXIS 410 (Pa. Super. Ct. 1980).

Opinion

McGOVERN, J.,

— Plaintiff in this case is a 76 year old woman who was transferred from the psychiatric facility, of additional defendant, Crozer-Chester Medical Center, to defendant, Chester Extended Care Center, suffering from “organic brain syndrome,” at approximately 2:00 p.m. on June 13, 1975. At approximately 8:15 p.m. on June 13, 1975, plaintiff exited a window in her second floor room at defendant’s facility, thereby sustaining extensive injuries. The trial court granted additional defendant’s motion for a nonsuit as to Crozer-Chester Medical Center, said motion having not been obj ected to by plaintiff. Thereafter, the jury returned with a verdict in favor of defendant and against plaintiff.

Plaintiff now moves for a new trial arguing that the trial judge committed reversible error in its instruction to the jury concerning the standard of care to be applied in deciding the issue of contributory negligence and in its instruction to the jury concerning defendant’s relationship to plaintiff in deciding the issue of the negligence of defendant.

In regard to plaintiff’s first contention, the trial court instructed the jury that plaintiff was subject to the so-called “reasonable man” standard in evaluating the issue of plaintiff’s contributory negligence; however, the jury was also extensively instructed concerning the evaluation of the circumstances of this incident, including the reasons for plaintiff’s presence at defendant’s facility, the knowledge of both plaintiff and defendant, and the conduct of both plaintiff and defendant.

Plaintiff suggests that the trial court develop a charge which requires the jury, in evaluating contributory negligence, to apply the law analogously to the situation wherein a child’s contributory negligence must be evaluated. It would thus appear [772]*772that plaintiff would have the trial court instruct the jury that it must ascertain the particular level of mental competency and mental awareness of a particular plaintiff and then apply a standard of care which it attributes to a person with that degree of mental competency and mental awareness prior to determining whether or not contributory negligence exists. While there may be some esoteric areas of science which allow for analysis of conduct in light of one’s intelligence quotient or mental competency, acuteness and awareness; it has long been recognized in Anglo-American jurisprudence that it is impossible for the layman to ascertain specific mental states at a given point in time with a sufficient degree of accuracy so as to insure that justice is provided in a jury trial courtroom.

It is further clear that human experience, at least as it has been analyzed and recorded, does not comport with plaintiff’s understanding of human conduct. There is no empiric evidence allowing the conclusion that the degree of a person’s mental competency or intellectual acuteness bears any realistic relationship to such person’s negligent or tortious conduct.

Plaintiffis recommended standard further suggests to this court that the entire matter of plaintiff’s intelligence quotient or acuteness or competency is to be left to the jury and that each juror then would ascertain the particular level, of plaintiff’s competency as he or she saw it at the material point in time and then apply some undefined adjusted or weighted standard of care. Plain-biff carefully avoids defining that standard of care; and such avoidance is understandable because to expect that a trial court would be in a position to communicate rationally in understandable terms to [773]*773a jury the concept of weighted care related to a particular state of mind at a given point is unrealistic, awkward and counterproductive to the concept of equal justice. Justice can only be comported to the extent that understandable principles of law can be equally applied in a series of decisions involving human conduct. The suggestion that the standard itself must be varied according to the infinitely multifaceted discernible effects of the human brain is, we respectfully suggest, not to be adopted as a theory of jurisprudence, and could well be considered rash by some.

Plaintiff also overlooks the aspect of the trial court’s charge in this case and the law, as at least we see it to be, that although a reasonable man standard is to be applied, the jury may consider the relevant circumstances of plaintiff’s position or condition at the time of the incident in question. So, if a plaintiff is intoxicated or asleep or somnambu-lant or in any one of a number of physical states or mental states or conditions, those circumstances are relevant to an evaluation of the plaintiff’s conduct, but they are circumstances to which a standard is applied, not a standard in and of itself. A standard is not changed before its application, since then the standard would be as varying as the level of human circumstances and judicial understandings of that circumstance. If such a variable rule is to be applied to the potential variable circumstances of plaintiffs generally, then (applying a variable to a variable) indeed there would be no vehicle to assure that all jurors deciding a matter would be acting upon the same legal principles. There could be no discernible or rational standard of justice. The Superior Court addressed this issue in Fredericks v. Castora, 241 Pa. Superior Ct. 211, [774]*774215-16, 360 A.2d 696, 698, (1976), when it declined to apply a higher standard of care (to vary with the experience of defendant), as requested by plaintiff. There, the court stated that:

“Other jurisdictions have confronted the problem of varying degrees of care and sought to control the ceaseless variation of the concept of negligence by establishing a single standard: ‘care does not increase or diminish by calling it names. We think the abstract concept of reasonable care is in itself quite difficult enough to grapple with and apply in our law without our courts gratuitously conferring honorary degrees upon it. There is only one degree of care in the law, and that is the standard of care which may reasonably be required or expected under all the circumstances of a given situation. . . .’ Spence v. Three Rivers Building & Masonry Supply, 353 Mich. 120, 130, 90 N.W. 2d 873, 878 (1958). Cf. Hoover v. Pennsylvania R. R. Co., 405 Pa. 642, 177 A. 2d 98, cert. denied, 369 U.S. 873, 82 S.Ct. 1142, 8 L.Ed. 2d 276 (1962); Schiele v. Motor Freight Express, Inc., 348 Pa. 525, 36 A. 2d 467 (1944).”

Accordingly, the proper standard of care is that of the reasonable man, to be applied considering the circumstances of the parties and the incident. This is the instruction elaborated upon in the instant charge and, therefore, plaintiff’s motion for new trial upon this basis should be denied.

It is further noted that, even assuming arguendo that plaintiff’s request for charge was an accurate statement of the law, in the case at bar there was not a scintilla of evidence suggesting plaintiff was disabled or mentally deficient. The evidence indicated that a member of plaintiff’s family was aware [775]*775of her condition, her presence and her location in defendant’s facility. The evidence also indicated that immediately preceding the incident in question there was a member of defendant’s staff who was in fact with plaintiff in her room and observed no signs of difficulty.

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Related

Spence v. Three Rivers Builders & Masonry Supply, Inc.
90 N.W.2d 873 (Michigan Supreme Court, 1958)
Hoover v. Pennsylvania Railroad
177 A.2d 98 (Supreme Court of Pennsylvania, 1962)
Fredericks v. Castora
360 A.2d 696 (Superior Court of Pennsylvania, 1976)
Schiele v. Motor Freight Express, Inc.
36 A.2d 467 (Supreme Court of Pennsylvania, 1944)
Nelson v. Moore-McCormack Lines, Inc.
369 U.S. 873 (Supreme Court, 1962)

Cite This Page — Counsel Stack

Bluebook (online)
15 Pa. D. & C.3d 770, 1980 Pa. Dist. & Cnty. Dec. LEXIS 410, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-v-chester-extended-care-center-pactcompldelawa-1980.