In Cohen v. Petty, 65 F.2d 820 (D.C. Cir. 1933), for example, the plaintiff was denied recovery where the defendant suffered a sudden fainting spell, lost control of his car and injured the plaintiff. The plaintiff lost in Cohen because the defendant did not owe her an absolute duty to avoid injuring her, but only a duty to exercise reasonable care to prevent injuries from his driving. Where injury results despite the exercise of reasonable care, that duty has not been breached, and the injured party cannot recover under a negligence standard.