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Guillory v. Louisiana Farm Bureau Casualty Insurance Co.

Citations: 604 So. 2d 87; 1992 La. App. LEXIS 1944; 1992 WL 143291Docket: No. 91-250

Court: Louisiana Court of Appeal; June 24, 1992; Louisiana; State Appellate Court

Narrative Opinion Summary

This case revolves around a tort action resulting from a vehicular collision involving Guillory's pickup truck and Spears's farm tractor. Guillory initiated the lawsuit against Spears and Louisiana Farm Bureau Casualty Insurance Company, citing Spears's alleged fault and violation of LSA-R.S. 32:385 concerning farm vehicles on public highways. Despite the jury's initial verdict absolving Spears of fault, the trial court granted Guillory's motion for judgment notwithstanding the verdict (JNOV), reallocating equal fault to both parties and awarding Guillory $200,000 in damages. The trial court emphasized Spears's purported illegal operation of the tractor and Guillory's intoxication as contributing factors. However, upon appeal, the appellate court reversed the trial court's JNOV, reinstating the jury's verdict. The appellate court underscored the jury's role in weighing evidence and determining fault, noting Guillory's impairment and the tractor's lights as factors supporting the jury's findings. Ultimately, the appellate court concluded that the trial court erred in its judgment, favoring Spears and the insurance company, and required Guillory to bear the costs of the proceedings.

Legal Issues Addressed

Contributory Negligence and Impairment

Application: Guillory's intoxication was a significant factor in the collision, which contributed to the jury's finding of his fault.

Reasoning: Testimony indicated that Guillory's intoxication impaired his ability to perceive and react, contributing to the collision which occurred when he crossed into Spears’s lane.

Judgment Notwithstanding the Verdict (JNOV) Standards

Application: The trial court granted a JNOV favoring Guillory, reallocating fault equally between the parties, despite the jury's verdict finding Spears not at fault.

Reasoning: The excerpt references legal standards for motions for judgment notwithstanding the verdict (JNOV) as established in Louisiana case law, particularly the Rougeau and Alumbaugh decisions.

Jury's Role in Determining Fault

Application: The appellate court reinstated the jury's verdict, emphasizing its role in assessing evidence and determining fault, contrary to the trial court's JNOV.

Reasoning: The appellate court found that the trial court erred in granting the JNOV, emphasizing the jury's determination of fault and therefore reversed the trial court's decision, reinstating the jury's original verdict.

Violation of Safety Statutes and Negligence

Application: Guillory claimed Spears violated LSA-R.S. 32:385, impacting liability determination, but the court found no significant contribution to the collision.

Reasoning: Proof of the applicability of LSA-R.S. 32:385 or the culti-packer's traversal of Guillory's lane does not automatically establish liability for Spears.