Young v. Clark Case Brief
Summary of Young v. Clark, 814 P.2d 364 (Colo. 1991)
Facts: P and D were both traveling on the same road and the road went through a construction zone. An unknown driver quickly changed to the left lane and then quickly came back into the center lane. This caused the drivers behind, including P, to quickly apply their brakes. D who was behind P was looking behind her shoulder because she was about the change lanes. Her passenger yelled that the cars in front were slowing down. D applied brakes but was unable to stop and hit P in the rear.
Procedure: The trial judge in instructing the jury gave the instruction of the sudden emergency doctrine and the jury found D not liable for negligence.
Issue: Did the trial ct. err by giving the sudden emergency instruction in the current case?
Sudden Emergency Doctrine: “The basis of the special rule is merely that the actor is left no time for adequate thought, or is reasonably so disturbed or excited that the actor cannot weigh alternative course of action, and must make a speedy decision, based very largely upon impulse or guess.” We still require the actor to act reasonably under the given facts.
Rationale: In the current case, the evidence shows that D was not following too closely behind P and D was not speeding. The actions of the unknown driver caused P to suddenly apply brakes and the ct. believed that the actions of the unknown driver make the instruction of sudden emergency doctrine to the jury valid.