Stewart v. Motts

Supreme Court of Pennsylvania · Torts

TortsNegligenceJury InstructionsDangerous Instrumentalitiesreasonable caredangerous instrumentalitiesgasolinehigher degree of care

Facts

On July 15, 1987, Stewart stopped at Motts' auto repair shop and helped Motts work on an automobile fuel tank. To start and move the car while the gasoline tank was unattached, Stewart suggested and then poured gasoline into the carburetor while Motts was to turn the ignition key at the appropriate moment. The car backfired, causing an explosion, and Stewart suffered severe burns to his upper body. At trial, Stewart requested a jury instruction stating that gasoline required a high degree of care, but the trial court refused it and the jury found for Motts.

Issue

In a negligence action involving gasoline, does Pennsylvania recognize a separate heightened standard of extraordinary or high-degree care beyond reasonable care, such that the trial court erred by refusing to instruct the jury that Motts had to use a high degree of care in handling gasoline? Also, were the instructions actually given inadequate or fundamentally erroneous?

Rule

Pennsylvania recognizes only one standard of care in negligence actions involving dangerous instrumentalities: reasonable care under the circumstances. The amount of care required is proportionate to the danger involved, so greater danger requires greater caution, but this does not create a separate legal standard of extraordinary care.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Pittsburgh, Dana Ortiz stored several canisters of industrial solvent in her workshop while her neighbor, Leo Mercer, helped move equipment nearby. One canister leaked, ignited, and injured Leo, who sued Dana for negligence and requested a jury instruction that anyone handling highly flammable chemicals owes an "extraordinary duty of care."

How should the court rule on Leo's requested instruction?

Explanation. The majority recognized only one negligence standard: reasonable care under the circumstances. Dangerous instrumentalities do not create a separate legal standard of extraordinary or heightened care; instead, the amount of caution required under reasonable care increases in proportion to the danger involved. Thus, the requested instruction improperly states a distinct standard.