Board of County Commissioners of Teton County v. Bassett

Quick Summary

The case involves Rayce B. Bassett (plaintiff) against the Wyoming Highway Patrol and Teton County Sheriff’s Department (defendants) following a car collision during a police chase. The dispute centered on whether the fleeing suspect’s willful and wanton conduct should be considered in determining liability.

The Supreme Court of Wyoming concluded that all forms of negligence should be compared under the state’s comparative fault statute and remanded for a new trial with specific instructions regarding causation and fault allocation.

Facts of the Case

In a dramatic incident involving a high-speed car chase, Rayce B. Bassett (plaintiff) found himself in harm’s way. Officers from the Wyoming Highway Patrol (defendant) were in hot pursuit of a suspect named Ortega.

Deputies from the Teton County Sheriff’s Department (defendant) set up a roadblock in an attempt to halt Ortega’s escape. Bassett, unsuspecting of the danger ahead, was driving toward the roadblock when he encountered the police activity.

Bassett was allowed to pass through the roadblock by the officers, only to be struck by Ortega’s vehicle shortly thereafter, resulting in injuries. In response, Bassett initiated a negligence lawsuit against the Wyoming Highway Patrol, the Sheriff’s officers, and the National Park Service.

The legal dispute arose from the officers’ actions during the chase and roadblock operation and their failure to properly warn Bassett of the imminent danger posed by Ortega’s approach.

Procedural History

The plaintiff filed a negligence claim against the Wyoming Highway Patrol, Teton County Sheriff’s officers, and the National Park Service.
The district court ruled that Ortega’s fault, being willful and wanton, should not be considered by the jury.
A jury verdict favored Bassett, allocating fault among the defendants but excluding Ortega.
The defendants appealed to the Supreme Court of Wyoming.

I.R.A.C. Format

Issue

Whether the conduct of Ortega, being willful and wanton, should have been included in the jury’s consideration for allocating fault under Wyoming’s comparative fault statute?

Rule of Law

The comparative fault statute in Wyoming mandates that fault includes conduct that is ‘in any measure negligent,’ encompassing willful and wanton behavior for the purpose of allocating responsibility.

Reasoning and Analysis

The Supreme Court of Wyoming determined that the lower court erred in not including Ortega as an ‘actor’ whose conduct should be compared with that of the other parties when determining fault. The court reasoned that all forms of culpable behavior should be included under the statute’s broad definition of ‘fault.’

This interpretation aligns with legislative intent to both apportion fault properly and eliminate joint and several liability, ensuring that each defendant is only liable for their proportionate share of fault.

Additionally, the court found that the defendants were entitled to an instruction based on the causation rule from DeWald v. State, which states that an officer’s pursuit is not the proximate cause of third-party injuries unless the officer’s conduct is extreme or outrageous. This standard applies to causation, not duty, which must be explained to the jury separately.

Conclusion

The Supreme Court reversed and remanded for a new trial, with instructions to include Ortega among those whose conduct would be compared for fault allocation and to apply the causation rule from DeWald concerning police liability.

Key Takeaways

Wyoming’s comparative fault statute requires considering all forms of culpable conduct for fault allocation, including willful and wanton behavior.
The causation standard from DeWald v. State applies to police pursuits resulting in third-party injuries; police conduct must be extreme or outrageous to establish proximate cause.
The Supreme Court of Wyoming reversed the lower court’s decision and remanded for a new trial with specific directions on including all relevant actors in fault comparison and applying proper causation instructions.

Relevant FAQs of this case

What constitutes willful and wanton behavior in the context of comparative fault?

Willful and wanton behavior is conduct that shows a deliberate disregard for the rights and safety of others. In comparative fault, such behavior often results in a higher degree of fault assigned to the party engaging in this egregious conduct.

For example: A driver speeding in a school zone and texting while driving shows willful and wanton disregard for safety, likely increasing their fault percentage if an accident occurs.

How does the legal principle of proximate cause apply to police pursuits?

Proximate cause in police pursuits refers to a standard where the officer’s actions must be more than just a contributing factor; they must be so extreme or outrageous that they directly lead to third-party injuries for liability to be established.

For example: If an officer pursues a suspect at high speed through a crowded pedestrian area, disregarding public safety protocols, their actions could be considered the proximate cause of any resultant harm.

In what way does comparative fault apportion liability among multiple defendants?

Comparative fault divides responsibility among all parties involved based on their respective contributions to the harm. Each defendant’s percentage of fault determines the amount they owe in damages.

For example: If two drivers are found responsible for a car accident, comparative fault may assign 70% responsibility to one for running a red light, and 30% to another for speeding, affecting how damages are awarded.

References

Last updated January 8, 2024

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