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Ramey v. Knorr10/17/2005
JUDGES: Concurring: H Joseph Coleman Marlin Appelwick
UNPUBLISHED
Insanity and other mental incapacities are not generally recognized as defenses to a claim of negligence. Some jurisdictions permit a limited exception to this rule by permitting sudden mental incapacity as a defense for a tortfeasor. This defense requires a defendant to establish '(1) {they had} no prior notice or forewarning of {their} potential for becoming disabled, and (2) the disability renders {them} incapable of conforming to the standards of ordinary care.' We hold that there is no legally sufficient evidentiary basis for a jury to find that Nancy Knorr ('Knorr') was entitled to the defense of sudden mental incapacity. Thus, the trial court properly granted Lanette Ramey's motion for judgment as a matter of law. Moreover, the court properly exercised its discretion in refusing the jury instructions Knorr offered and in giving the jury instructions that it gave. We also hold that the trial court correctly denied Knorr's motion for summary judgment as well as her alternative post-trial motions. We affirm.
This personal injury action arises from a head-on automobile collision on I-405. While in a delusional state, Knorr turned her car around towards oncoming traffic, removed her seatbelt, and drove head-on into Ramey's car. At the time of the incident, Knorr believed she was the object of a conspiracy to attack her. She was trying to commit suicide. Ramey suffered substantial injuries from the collision. She sued Knorr for negligence. Knorr raised the defense of sudden mental incapacity. Pre-trial, the trial court denied Knorr's motion for summary judgment. At the close of all the evidence at trial, both Knorr and Ramey moved for directed verdicts. The trial court granted a directed verdict for Ramey, ruling that as a matter of law, Knorr's sudden mental incapacity defense could not be sustained on the basis of the evidence. The jury returned a verdict for Ramey in the amount of $497,578.00. The trial court denied Knorr's post-trial motion for judgment as a matter of law or, alternatively, a new trial.
Following entry of judgment on the jury verdict, Knorr appealed.
CR 50 MOTIONS
Knorr argues that the trial court erred in denying her motions for a judgment as a matter of law and in granting Ramey's motion for a directed verdict. We disagree.
A directed verdict may be granted only if 'there is no legally sufficient evidentiary basis for a reasonable jury to find or have found for that party with respect to that issue.' A motion for a directed verdict admits the truth of the evidence of the non-moving party and all inferences that reasonably can be drawn therefrom. The evidence must be considered in the light most favorable to the nonmoving party. The trial court may grant a directed verdict only when it can be held that as a matter of law, there is no evidence, nor reasonable inferences from the evidence, to sustain the verdict. This court reviews a motion for a directed verdict de novo.
Insanity and Other Mental Deficiencies as Defenses
Both for historical and other reasons, insanity or other mental deficiencies generally are not recognized as defenses to negligence. Washington, along with the majority of states, holds the mentally ill to the standard of a reasonable person under like circumstances.
Traditionally, courts have relied on several rationales to hold the mentally ill to an objective standard of liability for negligence. The most common justification is that innocent victims should be compensated for their injuries. Another common reason is that the existence and degree of one's mental illness can
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