Williams v. Bright

Appellate Division of the Supreme Court of New York, First Department · Torts

TortsMitigation of damagesReligious beliefsConstitutional limits in civil trialsavoidable consequencesfailure to mitigatereasonably prudent personJehovah's Witness

Facts

Plaintiff Robbins was injured as a passenger in a car accident caused when her father, the driver, apparently fell asleep at the wheel. She suffered severe hip and knee injuries, and the medical proof showed that without surgery she faced likely necrosis and a wheelchair-bound life, while surgery offered a good recovery and near normal life. Robbins, a devout Jehovah's Witness, refused the recommended surgeries because they would necessarily require blood transfusions forbidden by her faith. At trial, the court instructed the jury to decide whether she acted reasonably as a Jehovah's Witness, without questioning the validity or propriety of her beliefs.

Issue

When an injured plaintiff refuses medically recommended treatment for religious reasons, must mitigation of damages be judged by the ordinary reasonably prudent person standard, or by a religion-specific 'reasonable believer' standard? Relatedly, may the court or jury evaluate the reasonableness or validity of religious doctrine in deciding mitigation?

Rule

An injured plaintiff's duty to mitigate damages remains governed by the objective reasonably prudent person standard. The plaintiff may present evidence that her religious beliefs motivated refusal of treatment, and that belief may be considered as one factor among all the circumstances in deciding reasonableness, but the court may not substitute a religion-specific standard, endorse the belief, or permit theological proof or adjudication of the validity or orthodoxy of religious doctrine.

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After a delivery truck struck Nina Patel in Buffalo, surgeons told her that a routine operation would likely restore most of her mobility, but that the procedure might require a blood transfusion. Nina refused because her faith forbids transfusions, and at trial the judge instructed the jury to decide whether she acted as a reasonable adherent of her religion.

Was that jury instruction proper?

Explanation. The majority held that mitigation remains governed by the objective reasonably prudent person standard. The plaintiff may present evidence that religious belief motivated refusal of treatment, but the court may not substitute a religion-specific 'reasonable believer' standard. Nor should the jury be told to ignore the belief completely; it may consider that belief as one factor under all the circumstances. (Derived from Williams v. Bright (n.d.).)