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Griffel v. Faust

Citations: 668 P.2d 247; 205 Mont. 372; 1983 Mont. LEXIS 759Docket: 82-145

Court: Montana Supreme Court; August 24, 1983; Montana; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves a personal and property injury lawsuit filed by the plaintiff against multiple defendants following a vehicular incident. The incident occurred when a defendant's vehicle broke down, resulting in the plaintiff colliding with the parked hay grinder. The jury found the plaintiff 100% negligent, awarding damages to the defendants. On appeal, the plaintiff challenged the sufficiency of the evidence and the trial court's exclusion of a proposed jury instruction. The appellate court maintained the jury's verdict, applying a limited standard of review that requires substantial evidence to support the jury's findings. The court concluded that substantial evidence existed to support the jury's determination that the defendants were not negligent and that the plaintiff's actions were the proximate cause of the accident. The court also addressed the plaintiff's claim of negligence per se, explaining that a statutory breach must be the proximate cause of an accident to be relevant, which the jury found was not the case here. Consequently, the jury's special verdict was upheld, affirming that the plaintiff's negligence was the sole proximate cause of the damages incurred.

Legal Issues Addressed

Jury's Role in Resolving Factual Disputes

Application: The jury is responsible for resolving factual questions, and courts defer to the jury's findings unless there is no reasonable evidence supporting their conclusions.

Reasoning: The court emphasizes that factual questions should be resolved by the jury, and reasonable minds may reach different conclusions based on the evidence.

Motion for New Trial

Application: A motion for a new trial will not be granted unless the moving party demonstrates clear and convincing evidence of error. The plaintiff's motion was denied as he failed to establish such error.

Reasoning: The court also notes that the jury's verdict was not disturbed by the trial court's denial of the plaintiff's motion for a new trial, as the plaintiff failed to demonstrate clear and convincing evidence of the trial court's error.

Negligence Per Se

Application: To establish negligence per se, the plaintiff must demonstrate a breach of statutory duty by the defendants. In this case, the plaintiff alleged negligence per se based on the defendants' violation of specific traffic statutes.

Reasoning: The plaintiff claims insufficient evidence to support the jury's finding of no negligence by the defendants, alleging that the defendants were negligent per se for violating specific statutes.

Proximate Cause in Negligence

Application: For negligence per se to be applicable, the statutory violation must be the proximate cause of the accident. The jury found that no act of the defendants constituted a proximate cause of the accident.

Reasoning: The jury found no negligence on the part of the defendants that was a proximate cause of the accident, effectively rejecting the plaintiff's argument.

Standard of Review for Jury Verdicts

Application: The court applies a limited standard of review for jury verdicts, requiring substantial evidence to uphold a verdict. A verdict will be maintained unless there is a complete absence of supporting evidence.

Reasoning: The court applies a limited standard of review regarding the sufficiency of evidence in jury verdict cases, where a substantial evidence threshold must be met for a verdict to stand.