Wilson v. Sibert – Case Brief Summary
Summary of Wilson v. Sibert, 535 P.2d 1034 (Alaska 1975).
Sibert (D) was in line in his car at a bank drive-up teller and Wilson (P) was in a car five feet behind him. Sibert hastily drove his car in reverse to avoid another car backing up immediately in front of him and struck Wilson’s car. Wilson sued for damages.
At trial Sibert testified that he had acted merely on reflex and admitted that he had not known whether there was a car behind him at the time. The jury was instructed regarding negligence and the sudden emergency doctrine. The jury returned a verdict in favor of Sibert and Wilson appealed.
What standard must a jury apply in determining whether a party is liable for negligence?
Holding and Rule
The law requires a jury to weigh the actions of a person charged with negligence against the standard of conduct of a reasonable person in the same circumstances.
The court held that the jury was bound to evaluate the reasonableness of Sibert’s actions in light of the evidence, which showed that he was in an emergency situation when he acted. The jury found that Sibert had acted properly. It was not error for the court to give the jury instructions for negligence in the context of emergency circumstances.
See Vaughan v. Menlove for a torts case brief involving the common law rule of negligence and duty of care owed by landowners. The court applied a reasonable person standard in holding landowners owe a general duty of care to use their land without causing harm to others through negligence.