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Agee v. Kahului Trucking & Storage, Inc.
Citations: 688 P.2d 256; 67 Haw. 365Docket: NO. 9146
Court: Hawaii Supreme Court; September 27, 1984; Hawaii; State Supreme Court
In the case of James O. Agee v. Kahului Trucking Storage, Inc., the Supreme Court of Hawaii affirmed the trial court's decision following a personal injury lawsuit where the jury found no negligence on the part of the defendant, KCC. Agee claimed that a softball-sized lump of raw sugar from KCC's trailer shattered his truck’s windshield, causing injuries. However, Agee did not witness the object detach from the truck, only seeing it in the air, and his testimony did not establish that KCC controlled the object that caused the injury. Agee requested to apply the doctrine of res ipsa loquitur, which requires evidence that the defendant had control over the object causing the injury. The trial court denied this request, finding insufficient evidence to support it. The court also granted KCC's "mere happening" instruction, which Agee argued was prejudicial, but the court disagreed. Overall, the Supreme Court found no errors in the trial court's decisions regarding jury instructions. Instructions given to a jury must be evaluated in their entirety and in the context of all relevant evidence. The focus on review is not on the technical correctness of individual instructions but on whether the appellant experienced prejudice as a result. A court's failure to provide a relevant instruction that accurately states the law is considered prejudicial unless adequately covered by other instructions. Erroneous instructions are generally viewed as harmful and can be grounds for reversal unless the record shows the error was not prejudicial. In this case, the trial court provided comprehensive instructions regarding negligence, proximate cause, and burden of proof. After reviewing all instructions, it was determined that instruction number 3 did not prejudice the appellant, Agee, and that the jury's verdict was well-supported by evidence. Agee's additional arguments were found to lack merit, resulting in an affirmation of the decision. Additionally, Agee's requested instruction regarding the inference of negligence and KCC's instruction concerning the inference from the occurrence of an accident were noted.