Brief Fact Summary. Pilot error caused an airplane crash, killing the pilot and the passengers.
Synopsis of Rule of Law. A professional standard of care is not a subjective standard, it is an objective standard predicated on the rules and guidelines of the profession.
Issue. Whether professionals should be held to an industry standard of care or one that is predicated on their individual experiences and training.
Held. The proper standard of care for professional negligence is an objective standard, using minimum industry standards and not looking into the individual’s actual training or experience. The jury instruction instead created a subjective standard by focusing on the defendant’s personal training.
Discussion. The jury instructions in this case imposed a subjective standard by asking the jury to decide if the pilot acted in a reasonably prudent manner given the pilot’s own particular experience and training. Instead, the pilot’s actions are to be measured by an industry standard that is applicable to all pilots. By using an objective standard the court avoids imposing a different standard of care for each case.