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Farwell v. Keaton, 396 Mich. 281, 240 N.W.2d 217

Facts

On August 26, 1966, David Siegrist and Richard Farwell were social companions who consumed alcohol and followed two girls to a restaurant. After being chased by a group of boys, Farwell was severely beaten. Siegrist found him injured and applied ice to his head but did not take him to the hospital. Instead, he drove around for hours before leaving Farwell in the back seat of his car at his grandparents' home, where he was later found unconscious and died three days later from an epidural hematoma.

Factually, it appears that, on August 26, 1966, Richard Murray Farwell, deceased eighteen-year-old son of the plaintiff, visited the home of his friend, David Siegrist, a sixteen-year-old; that evening they drove to a trailer rental lot, where Siegrist was returning an automobile he had borrowed from a friend who was employed by the rental agency.

Issue

Did David Siegrist have a legal duty to obtain medical assistance for Richard Farwell after he was injured?

Two separate, but interrelated questions are presented: A. Whether the existence of a duty in a particular case is always a matter of law to be determined solely by the Court? B. Whether, on the facts of this case, the trial judge should have ruled, as a matter of law, that Siegrist owed no duty to Farwell?

Rule

A duty in negligence cases is defined as an obligation to conform to a particular standard of conduct toward another, and whether a duty exists can be a question of law or fact depending on the circumstances.

‘A duty, in negligence cases, may be defined as an obligation, to which the law will give recognition and effect, to conform to a particular standard of conduct toward another.’ Prosser, Torts (4th ed.), s 53, p. 324.

Analysis

The court determined that Siegrist had a duty to act as a reasonable person after he voluntarily attempted to aid Farwell. The evidence showed that Siegrist was aware of Farwell's injuries and failed to seek medical help, which the jury found constituted a breach of his legal duty. The court emphasized that the jury must decide whether Siegrist's actions were reasonable under the circumstances.

The jury in this case found that Siegrist did not act reasonably, and that his negligence was the proximate cause of Farwell's death.

Conclusion

The Supreme Court reversed the Court of Appeals' decision and reinstated the jury's verdict, affirming that Siegrist's negligence was a proximate cause of Farwell's death.

The Court of Appeals is reversed and the verdict of the jury reinstated.

Who won?

The plaintiff, Richard Farwell's father, prevailed because the jury found that Siegrist failed to exercise reasonable care after coming to Farwell's aid, which was a proximate cause of Farwell's death.

1 There is ample evidence to support the jury determination that David Siegrist failed to exercise reasonable care after voluntarily coming to the aid of Richard Farwell and that his negligence was the proximate cause of Farwell's death.

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