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Hampton v. Lynch Motor Co.

Citations: 6 Wash. App. 644; 495 P.2d 345; 1972 Wash. App. LEXIS 1220Docket: No. 422-3

Court: Court of Appeals of Washington; March 31, 1972; Washington; State Appellate Court

Narrative Opinion Summary

The case involves an appeal by the plaintiff, who sustained personal injuries from falling into a grease trap on the premises of Lynch Motor Company. The primary legal issues revolved around the plaintiff's status on the premises as a business invitee versus a licensee, the duty of care owed, and contributory negligence. The plaintiff argued that she was a business invitee, as she was on-site to potentially purchase a car and had purchased gasoline, which could benefit the defendant. The court referenced relevant case law to affirm her invitee status, finding the trial court erred in instructing the jury on the duties owed to a licensee. Additionally, the court evaluated the plaintiff's contributory negligence, noting that her route choice could be seen as imprudent. The court also examined the instructions regarding temporary unsafe conditions and found no evidentiary support for them. The appellate court reversed the original judgment, highlighting the necessity of proper jury instructions concerning invitee status and contributory negligence considerations. A rehearing petition was denied, and the Supreme Court declined further review.

Legal Issues Addressed

Contributory Negligence

Application: The court found that the plaintiff's decision to walk a specific path raised questions about her contributory negligence, allowing the jury to consider whether she failed to maintain a proper lookout or acted imprudently.

Reasoning: The court disagreed, noting that the plaintiff's choice to walk between a tow truck and a building, rather than around the front of the truck, raised questions about her negligence.

Duty of Care Owed to Invitees

Application: The court determined that the area where the injury occurred fell within the invitation, and the instructions should have clarified the duty of care owed to the plaintiff as an invitee, not as a licensee.

Reasoning: The court determined that the area of injury fell within the invitation, mandating that instructions should clarify the plaintiff's status as an invitee and the corresponding duties owed by the defendant.

Ordinary Care and Hazard Awareness

Application: The court found no evidence indicating that the plaintiff was aware of the hazard posed by the iron cover, supporting the argument of contributory negligence for not noticing the cover's condition with ordinary care.

Reasoning: The court finds that there is no evidence indicating the plaintiff was aware of any hazard, nor was it apparent, as she was unaware of the iron cover's condition until her fall.

Status as Business Invitee versus Licensee

Application: The plaintiff was classified as a business invitee because her actions, such as purchasing gasoline and viewing cars, could potentially benefit the defendant, contrary to the defendant's claim that her visit offered no economic benefit.

Reasoning: The plaintiff contends that she was a business invitee due to purchasing gasoline and viewing cars, while the defendant argues that the visit offered no economic benefit, as the Hamptons' financial condition would have precluded a sale.

Temporary Unsafe Conditions and Defendant's Knowledge

Application: The court concluded that there was no evidence to support the instruction that the plaintiff needed to prove the unsafe condition was known to the defendant or existed long enough for discovery under ordinary care.

Reasoning: The court agrees with the plaintiff that there is no evidence to justify the instruction's application, leading to the conclusion that it should not have been given.