Bashi v. Wodarz

Brief Fact Summary.

Plaintiffs were involved in a car accident with Defendant. Plaintiffs brought a negligence claim against Defendant. Defendant claimed that her mental illness caused her to have the accident with Plaintiffs. Trial court granted Defendant’s motion for summary judgment. Plaintiffs appealed.

Synopsis of Rule of Law.

A mentally disabled person is subjected to the same standard of reasonable care as a sane person in a negligence cause of action.

Facts.

Mubarak Bashi and Nasim Akhtar (Plaintiffs) sued Margie Wodarz (Defendant) after being involved in a car accident. Defendant, prior to the accident with the plaintiffs, was involved in another car accident and left the scene. Defendant claimed that the onset of her mental illness caused the accident with Plaintiffs,

Issue.

Whether a mentally disabled person is subjected to the same standard of reasonable care as a sane person in a cause of action for negligence.

Held.

Yes. A mentally disabled person is subject to the same standard of care as a sane person in a claim for negligence. The reasonable person standard measures the conduct of a defendant against that of a reasonable person who was in a similar situation. This standard has been the common law rule for centuries. Allowing insane persons to have a special standard would force courts to make difficult distinctions amongst the various mental diseases. Moreover, there would be extreme difficulty for the factfinder in proving or disproving mental illness. Further, caretakers would be more likely to take greater care of the mentally ill persons knowing that a reasonable standard of liability would be imposed. Here, Wodarz argued that the sudden onset of her mental illness at the time of the incident. Therefore, she should not be held liable for Plaintiff’s negligence claim. Wodarz cited a case where the court held that a person may not be liable for damages that occurred as a result of sudden physical illness. However, the same rule is not applicable for sudden mental illnesses. Thus, Wodarz is subjected to the reasonable person standard and the court erred when granting Wodarz motion for summary judgment because of sudden mental illness. Trial court judgement was reversed

Discussion.

In a negligence case, the court distinguishes between sudden physical illnesses and sudden mental illnesses in determining if a defendant may be held liable for damages.