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Keywords

tortplaintiffappealtrialsummary judgmentwillpiracy
tortplaintiffappealtrialsummary judgmentwillpiracy

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Navarrete v. Meyer, 237 Cal.App.4th 1276, 188 Cal.Rptr.3d 623, 15 Cal. Daily Op. Serv. 6604, 2015 Daily Journal D.A.R. 7012

Facts

On November 26, 2009, Hayley Meyer was a passenger in a vehicle driven by Brandon Coleman. Meyer, familiar with the road's dips, encouraged Coleman to speed, stating it was fun to drive fast over them. After Meyer urged Coleman to go faster, he accelerated to 81 miles per hour before losing control and crashing into a parked vehicle, resulting in the death of Esteban Soto, who was attempting to secure his child in a car seat.

On November 26, 2009, Meyer was the front passenger in a vehicle driven by her friend Brandon Coleman. Another person, Levi Calhoun, was in the back seat. While driving to a nearby drugstore, Meyer told Coleman to turn onto Skyview Drive as a shortcut. Skyview Drive is a residential street with a 25 mile-per-hour speed limit. Meyer had been on Skyview Drive many times before that day, and she knew it had dips that would cause a car traveling at a high rate of speed to become airborne. While Coleman was making the turn onto Skyview Drive, Meyer told him about the dips, that it was fun to drive fast on them, and that he should do it. Shortly after Coleman turned onto the street, Meyer told Coleman to “go faster.” Coleman asked Calhoun if he should speed up, and Calhoun responded, “You probably shouldn't because you may mess up the car.” Coleman sped up. He accelerated to such a degree that he caught air from the dips and lost control of the car, which veered sharply to the right and collided into Navarette's parked vehicle while Navarrete's husband, Esteban Soto, was attempting to put one of their children in a car seat. Soto's legs were severed and he was killed by the impact.

Issue

Did Hayley Meyer willfully interfere with the driver's control of the vehicle and conspire with him to engage in an unlawful exhibition of speed, thereby causing the fatal accident?

Did Hayley Meyer willfully interfere with the driver's control of the vehicle and conspire with him to engage in an unlawful exhibition of speed, thereby causing the fatal accident?

Rule

A passenger can be held liable for aiding and abetting a driver's unlawful conduct if they encourage or assist the driver in committing a tortious act, and civil conspiracy can arise from verbal encouragement to commit a wrongful act.

A passenger can be held liable for aiding and abetting a driver's unlawful conduct if they encourage or assist the driver in committing a tortious act, and civil conspiracy can arise from verbal encouragement to commit a wrongful act.

Analysis

The court found that Meyer's encouragement to speed could be interpreted as aiding and abetting Coleman's unlawful conduct. The evidence suggested that her actions were a substantial factor in causing the accident, as she was aware of the road's conditions and still urged the driver to accelerate. The court determined that a reasonable jury could find that Meyer conspired with Coleman to engage in an unlawful exhibition of speed.

The court found that Meyer's encouragement to speed could be interpreted as aiding and abetting Coleman's unlawful conduct. The evidence suggested that her actions were a substantial factor in causing the accident, as she was aware of the road's conditions and still urged the driver to accelerate.

Conclusion

The Court of Appeal reversed the trial court's summary judgment in favor of Meyer, allowing the case to proceed to trial on the issues of aiding and abetting and civil conspiracy.

The Court of Appeal reversed the trial court's summary judgment in favor of Meyer, allowing the case to proceed to trial on the issues of aiding and abetting and civil conspiracy.

Who won?

The prevailing party on appeal was the plaintiffs, the Navarette family, as the court found sufficient evidence to warrant a trial on their claims against Meyer.

The prevailing party on appeal was the plaintiffs, the Navarette family, as the court found sufficient evidence to warrant a trial on their claims against Meyer.

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