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Keywords

defendantnegligenceliabilityappealtrialmotion
defendantnegligencetrialmotion

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Metts v. Griglak, 438 Pa. 392, 264 A.2d 684

Facts

The accident occurred on February 6, 1966, on Route 51 in Westmoreland County, where a bus owned by Perry Bus Lines struck the rear of an automobile driven by Mrs. Harshman. At the time, the highway was slippery and covered with snow and ice. Mrs. Harshman claimed that a Greyhound bus had passed her vehicle, causing her to lose control and subsequently be hit by the Perry bus. The jury found in favor of Metts against all defendants, but Greyhound contested this ruling, leading to the appeal.

The accident occurred on February 6, 1966, on Route 51 in Westmoreland County, where a bus owned by Perry Bus Lines struck the rear of an automobile driven by Mrs. Harshman.

Issue

Did the trial court err in granting Greyhound's motion for judgment n.o.v. based on the claim that the harm suffered by Metts was not a foreseeable result of Greyhound's alleged negligence?

Did the trial court err in granting Greyhound's motion for judgment n.o.v. based on the claim that the harm suffered by Metts was not a foreseeable result of Greyhound's alleged negligence?

Rule

A defendant can only be held liable for harms that are within the risk foreseeably created by their negligent conduct. The foreseeability of harm is a key factor in determining negligence.

A defendant can only be held liable for harms that are within the risk foreseeably created by their negligent conduct.

Analysis

The court analyzed whether the collision was a foreseeable result of Greyhound's operation of its bus at excessive speed. It concluded that the Greyhound bus was over half a mile away from the scene of the accident when it allegedly created a snow swirl, which did not constitute a foreseeable risk of harm. Furthermore, the court noted that the Perry bus driver, despite being unable to see due to the snow swirl, continued driving without reducing speed, which constituted intervening negligence that relieved Greyhound of liability.

The court analyzed whether the collision was a foreseeable result of Greyhound's operation of its bus at excessive speed.

Conclusion

The court affirmed the judgment n.o.v. in favor of Greyhound, concluding that even if Greyhound was negligent in exceeding the speed limit, the harm suffered by Metts was not a foreseeable consequence of that negligence.

The court affirmed the judgment n.o.v. in favor of Greyhound, concluding that even if Greyhound was negligent in exceeding the speed limit, the harm suffered by Metts was not a foreseeable consequence of that negligence.

Who won?

Greyhound prevailed in the case because the court found that the harm was not a foreseeable result of its actions, and the intervening negligence of the Perry bus driver was significant.

Greyhound prevailed in the case because the court found that the harm was not a foreseeable result of its actions, and the intervening negligence of the Perry bus driver was significant.

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