Law School Case Brief
Teply v. Lincoln - 125 Idaho 773
In civil actions for damages, where injury occurs as a proximate result of a violation of a statute enacted for the protection of motorists, such violation is negligence as a matter of law, and not merely prima facie evidence of negligence. Thus, one cannot excuse himself from compliance with a safety statute by showing that he did or attempted to do what any reasonably prudent person would have done under similar circumstances. Rather, the question of liability under the negligence per se theory turns not upon whether the defendant has demonstrated his freedom from common-law negligence, but on whether he has established a "legal excuse" for his violation of the statute.
Plaintiff injured persons filed a negligence suit arising from a vehicle collision. The district court entered a judgment in favor of the defendant driver. Plaintiffs appealed arguing that the driver failed to provide sufficient evidence that his violations of Idaho Code §§ 49-630 and 49-631, which constituted negligence per se and which occurred when he lost control of his pickup truck, crossed the centerline of the highway, and collided with plaintiffs' vehicle, were excused.
Is the defendant excused from complying with the safety statues where icy road conditions caused him to lose control of his vehicle?
The court ruled that, as a matter of law, a driver was not legally excused from compliance with safety statues relating to driving on the right-hand side of the highway where icy road conditions unexpectedly caused him to lose control of his vehicle and slide across the centerline of the highway. The court explained that where injuries occurred as approximate result of a violation of a statute enacted for the protection of motorists, as in the instant case, such a violation was negligence as a matter of law. One could not excuse himself from compliance with a safety statute by arguing that he acted reasonably in the given situation. Instead, the court explained that the individual had to establish a "legal excuse" for his violation of the statute.
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