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Keywords

negligencestatutetrialverdictcomparative negligence

statutetrialverdictjury instructions

Related Cases

Roberts v. Estate of Randall, 51 P.3d 204, 2002 WY 115

Facts

On February 7, 1998, two parties of snowmobilers collided on Greys River Road, a groomed snowmobile trail in Wyoming. The Roberts party, which included Robert H. Roberts and his family, was warned about the dangers of late travel on the trail. During the ride, Roberts and another snowmobiler, Randall, collided while traveling towards each other. The jury found that both parties contributed to the accident, with Roberts being more at fault.

The Greys River area on the Wyoming Range in western Wyoming is a popular recreational area. Greys River Road in the Bridger–Teton National Forest is a national forest service road (No. 10138) that is accessible for wheeled traffic in the summer but closed to that traffic during winter.

Issue

Whether the jury properly considered violations of motor vehicle statutes as evidence of negligence by snowmobile operators and whether the sudden emergency doctrine should have been applied.

The Robertses contend that motor vehicle statutes are not applicable to snowmobile operation and the jury instructions constituted errors entitling them to a new trial.

Rule

The court held that the Uniform Act Regulating Traffic on Highways applies to snowmobiles and that the sudden emergency doctrine is not a complete defense under comparative negligence statutes.

We hold that Wyo. Stat. Ann. §§ 31–5–101 through 1507 (Chapter Five) do apply, and the district court's jury instructions properly instructed on the applicable law.

Analysis

The court determined that the jury was correctly instructed on the applicable statutes governing snowmobile operation. It found that the evidence did not support the application of the sudden emergency doctrine, as Roberts had not acted with the care expected of a reasonable snowmobile operator in the circumstances leading to the collision.

The trial court determined that Article Two's provisions generally governing the operation of a vehicle were applicable and instructed the jury accordingly.

Conclusion

The Supreme Court affirmed the jury's verdict, concluding that the trial court's instructions were appropriate and that the evidence did not warrant a sudden emergency instruction.

We affirm the order of judgment on the verdict.

Who won?

The Estate of Steven Charles Randall prevailed because the jury found that Roberts was primarily at fault for the collision, and the court upheld the jury's findings.

The jury returned a verdict finding that Roberts was seventy-four percent at fault and Randall was twenty-six percent at fault.

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