Quick Summary
James Stevens (plaintiff) was struck by Aaron Veenstra (defendant), a minor in a driver’s education course. Stevens sued for negligence. The jury, instructed to use minor-specific standards, found for Veenstra.
The issue was whether a minor driver should be held to an adult standard of care. The Michigan Court of Appeals decided that despite being in driver’s education, minors must be held to an adult standard due to the risks involved in driving.
Facts of the Case
James Stevens (plaintiff) was injured when Aaron Veenstra (defendant), a 14-year-old student driver, collided with him during a driver’s education course. Veenstra, an academically advanced minor who had skipped grades and graduated from high school early, was taking the course to have transportation to college.
During the first driving lesson on public roads, Veenstra made a sharp turn and struck Stevens, who was exiting his parked vehicle. The incident led to Stevens filing a negligence suit against Veenstra.
Veenstra was supervised by a driving instructor at the time of the accident. The trial court instructed the jury to consider the standard of care for a minor of Veenstra’s age and experience, resulting in a verdict in favor of Veenstra.
Stevens appealed, challenging the appropriateness of the jury instructions and asserting that Veenstra should have been held to an adult standard of care due to the dangerous nature of driving.
Procedural History
- A negligence suit was brought against Aaron Veenstra by James Stevens.
- The trial court ruled in favor of Veenstra after instructing the jury to hold Veenstra to the standard of care for a reasonably careful minor.
- Stevens appealed the decision to the Michigan Court of Appeals on the grounds that the jury instructions were improper.
I.R.A.C. Format
Issue
Whether a minor engaged in a dangerous adult activity, such as driving, should be held to an adult standard of care or the standard of care for a reasonably careful minor.
Rule of Law
All drivers, including minors, are held to an adult standard of care when engaging in the dangerous activity of driving an automobile.
Reasoning and Analysis
The court acknowledged that while minors are generally held to a standard of care based on their age, mental capacity, and experience, there is an exception for activities like driving where the potential harm is significant. The court rejected the argument that being in a driver’s education course exempts a minor from adult standards.
It was reasoned that the inherent dangers of driving do not diminish with the driver’s age or lack of experience. Thus, all individuals operating a vehicle must adhere to a uniform standard of care for the safety of the public.
Conclusion
The Michigan Court of Appeals reversed the trial court’s decision and remanded for a new trial, holding that Veenstra should be held to an adult standard of care while driving.
Key Takeaways
- Minors engaged in driving are held to an adult standard of care regardless of their participation in driver’s education courses.
- The potential risks associated with driving necessitate a uniform standard of care applicable to all drivers, including minors.
- The appellate court can reverse a jury verdict if it finds that improper legal standards were applied during the trial.
Relevant FAQs of this case
What legal principles determine the standard of care required for a specific activity?
The standard of care is based on what a reasonable person would do under similar circumstances. It’s determined by considering factors such as the nature of the activity, potential risks involved, and the abilities of the individual engaging in the activity.
- For example: While walking their pet alligator on a leash, an individual must account for the unique dangers posed by the animal compared to walking a typical domestic dog. Despite both activities being ‘walking a pet,’ the inherent risks demand a heightened level of care.
How does a minor's capacity affect liability in tort cases?
In tort cases, a minor is often held to a different standard of care than an adult unless they engage in adult activities. For less dangerous activities, the reasonable person standard is adjusted to match a minor’s age and experience. However, for inherently dangerous activities that adults usually undertake, minors may be held to an adult standard of care.
- For example: If a 15-year-old is riding a bicycle on a public pathway and collides with a pedestrian, their liability would be judged based on what is expected of a reasonable person of their age and experience, unlike driving where the adult standard applies.
Under what circumstances can a uniform standard of care be imposed across different groups of individuals?
A uniform standard of care applies when the activity undertaken involves significant risks or requires special skills that do not vary with the personal characteristics of the individual. This ensures that all persons engaged in such activities are accountable for upholding public safety to the same degree.
- For example: A professional skydiving instructor and an amateur skydiver must both adhere to stringent safety protocols when jumping from an aircraft, regardless of their level of experience or age.
References
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