Popejoy v. Steinle Case Brief

Summary of Popejoy v. Steinle, S. Ct WY [1991]

Joint Enterprise

Relevant Facts: Mrs Steinle her daughter and niece while headed into town from their ranch, to purchase a calf for the daughter, collided with a truck driven by Popejoy. Mrs died and Popejoy was hospitalized with a neck injury. 15 mos later he began experiencing severe neck and back pain and underwent two surgeries. Following the second he unsuccessfully attempted to reopen Connie’s estate which had probated and closed over a yr earlier. He then filed a creditor’s claim against her husband’s estate which was rejected. He then filed a complaint against his reps claiming Mrs and Mr were engaged in a joint venture a business trip to get the calf that day.

Legal Issue(s): Whether joint venture relationship exists only when arrangement between parties was for business or pecuniary purpose, and j v existed at time of accident, as other motorist was transporting her daughter to pick up calf which would be raised by daughter separate and apart from cattle ranch operated by other motorist and husband?Court’s Holding: Yes, and No

Procedure: D Ct, entered judgment for estate and motorist appealed. The S Ct Affirmed.

Law or Rule(s): An agreement, express or implied, among the members of the group; a common purpose to be carried out by the group; a community of pecuniary interest in that purpose, among the members; AND an equal right to a voice in the direction of the enterprise, which gives an equal right of control.

Court Rationale: Burden of establishing existence of joint venture is upon party asserting that relationship exists. Joint adventurer relationship exists, for purposes of imputing liability for negligence of one alleged joint venturer to another, only to ventures having distinct business or pecuniary purpose. Wife was not joint adventurer with husband in operation of cattle ranch at time she was involved in automobile accident, so as to impute her alleged negligence to husband; requirement that distinct business or pecuniary purpose be pursued at time of accident was not met, as wife was driving daughter to pick up calf for daughter to raise, as a separate project and apart from normal operation of ranch.

Plaintiff’s Argument: The purchase of the calf, Mr. Steinle’s efforts raising and selling the calf created a pecuniary interest in the purchase.

Defendant’s Argument: The purpose of the trip was to purchase a calf for the daughter’s own interest, she solely derived the profits from that purchase not the parents.

A fact is “material,” for purposes of defeating summary judgment, if proof of that fact would have effect of establishing or refuting one of essential elements of claim or defense asserted by party.

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