Martin v. Herzog

Brief Fact Summary.

Plaintiff and husband were driving a buggy without headlights on a dark highway at night, violating a statute that requires headlights. Defendant rounded a curve on the highway in the opposition direction and crashed into plaintiff. The accident caused the death of plaintiff’s husband.

Synopsis of Rule of Law.

Unexcused omission of statute required signals is negligence itself.

Facts.

Plaintiff and her husband, while driving on a highway at night, were stuck by defendant’s car coming in the opposite direction. The collision killed plaintiff’s husband. Plaintiff sued defendant for his negligence. However, plaintiff and husband were traveling without headlights that were required by a highway statute. Defendant claimed that the accident was caused by plaintiff’s contributory negligence.

Issue.

Was the trial court correct in refusing defendant’s request to rule that the absence of a light on the plaintiff’s vehicle was prima facie evidence on contributory negligence.

Held.

The trial court was erred. The decision of the Appellate Division was ffirmed, which means this case was decided in favor of defendant.

Discussion.

This Court opined that the unexcused omission of the statutory signals is more than some evidence of negligence. It is negligence in itself. The state passed this requirement of headlights as a statutory requirement in order to guard the safety of people, and such a rule has become a norm in the state. Lights are intended for the guidance and protection of other travelers on the highway. By the very terms of the hypothesis, to omit, willfully or heedlessly, the safeguards prescribed by law for the benefit of another that he may be preserved in life or limb, is to fall short of the standard of diligence to which those who live in organized society are under a duty to conform.

The Court also clarified that while failing to follow this statute should be considered prima facie evidence of negligence, the jury should still consider the actual cause of the accident in determining if plaintiff could still receive damages.