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Knobloch v. Minzy
Citations: 181 Conn. 650; 436 A.2d 296; 1980 Conn. LEXIS 950
Court: Supreme Court of Connecticut; August 5, 1980; Connecticut; State Supreme Court
Kenneth Knobloch appealed a jury verdict in favor of defendants George W. Minzy and Arnold Stetson in a negligence case stemming from a May 1, 1973, motor vehicle accident. Knobloch, driving a Volkswagen, collided with Minzy's Ford pickup truck. The defendants asserted contributory negligence on Knobloch's part, leading the trial court to instruct the jury that if Knobloch's negligence was a proximate cause of his injuries, he could not recover damages. The jury ruled against Knobloch, who contended the court erred by not instructing the jury on comparative negligence. However, the applicable comparative negligence statute (General Statutes 52-572h) only became effective on October 1, 1973, after the accident, and prior legislation limited comparative negligence to certain cases involving private passenger vehicles. Knobloch argued that the pickup truck should be classified as a private passenger vehicle since it was used for noncommercial purposes. The court ultimately agreed that the trial court erred in not instructing the jury on comparative negligence, referencing the precedent set in Stoni v. Wasicki, which held that the comparative negligence doctrine could apply even if a non-private passenger vehicle was involved in the accident, indicating legislative intent to avoid the conflicting application of both doctrines in such cases. In both the Stoni case and the current matter, private passenger motor vehicles were involved in accidents attributed to operator negligence. The court highlights the inconsistency of applying comparative negligence in Stoni, where the defendant operated a private passenger vehicle, while applying contributory negligence in this case where the plaintiff did the same. Public Act No. 273 (1972) aimed to ease the strict application of contributory negligence for accidents involving such vehicles. The court concluded that the comparative negligence doctrine should apply uniformly, as established in Stoni, making the previous court's failure to apply this doctrine a clear error. Consequently, a new trial is ordered, and the court does not address the defendants’ cross-appeal claims. The relevant statutes emphasize that contributory negligence does not bar recovery if it is not greater than the combined negligence of the defendants, with damages adjusted accordingly. The repeal of Public Act No. 273 (1972) and its replacement with General Statutes, 52-572h, aimed to clarify the law's application. The court determined that the classification of the defendant’s vehicle as a private passenger vehicle is irrelevant to the case's outcome.