Hammontree v. Jenner

Court of Appeal of California (1971)

Facts: Jenner was driving home from work and crashed through the wall of the bicycle shop owned and operated by Maxine Hammontree and her husband. Maxine was struck and the car caused personal injuries and damage to the bicycle shop.

Jenner became unconscious during an epileptic seizure and that is why he lost control of the car. He admitted to having a medical history of epilepsy. Nineteen years prior he had been examined by neurologists who put him on medication to control his condition. He was on medication at the time of the accident and had no warning that he was about to have a seizure prior to the accident. The DMV was aware of Jenner’s condition and he visited a doctor every 6 months to one year and followed the DMV’s instruction in order to receive confirmation from a doctor whether or not it was safe for him to drive.

Issue: Is a person who drives with knowledge of a dangerous medical condition liable for injury if they become unconscious while driving?

Procedural History: The court did not grant summary judgment on the doctrine of liability. The trial court then refused to instruct the jury on the claim of absolute liability. The case was appealed from the Superior Court of Los Angeles County.

Rules: The court does not apply the doctrine of strict liability to automobile drivers. Principles of negligence govern personal injury cases arising out of automobile accidents.

Reasoning: The court distinguishes between superimposing strict liability on automobile drivers and product manufacturers. The ruling also distinguishes, by citing a previously decided case, that invoking strict liability on automobile drivers would cause confusion in determining liability in an accident. It would also likely contribute towards long investigations for insurance companies to issue compensation, which could cause more harm than good. The court states that “it is not enough to simply say… that the insurance carriers should be the ones to bear the cost of injuries to innocent victims on a strict liability basis.”

Holding: If the driver of an automobile with a medical condition capable of causing an automobile accident acted reasonably to control the condition, then the driver will only be held liable in cases that the driver acted negligently, and will not be held to the doctrine of strict liability. (Judgment affirmed.)

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