SIGNIFICANT CASE SUMMARIES

Virginia Case Summary

Boyette v. Sprouse
Virginia Supreme Court
No. 240135

Decided: January 23, 2025

The sudden emergency doctrine is applicable in a motor vehicle accident when evidence showed the sudden stop was compounded by other unusual events.

Background

On the night in question, Plaintiff was a passenger in a vehicle that was rear-ended by a second vehicle. The driver of Plaintiff’s vehicle rounded a corner and was blinded by the headlights of vehicles parked on the opposite side of the road. The vehicle then struck a large dog which suddenly appeared in front of the vehicle. The collision itself caused the vehicle to slow down on its own, without the driver hitting the brakes, such that there were no brake lights illuminated on the vehicle. Defendant, who was traveling in the same direction, rear-ended the Plaintiff’s vehicle after her vision was also obscured by the same headlights. Following the accident, Plaintiff sued Defendant for negligence.

Defendant requested a jury instruction on the sudden emergency doctrine. Plaintiff objected, arguing that the Virginia Supreme Court had previously held that the doctrine does not apply to traffic accidents. The Trial Court overruled Plaintiff’s objection and issued the instruction. The instruction stated that if Defendant faced a sudden emergency, defined as “an event or combination of circumstances that calls for immediate action without giving time for deliberate exercise of judgment,” and acted as a reasonable person would have under the circumstances, Defendant was not negligent. The jury returned a defense verdict. Plaintiff appealed to the Virginia Court of Appeals, which upheld the Trial court. Plaintiff then appealed to the Virginia Supreme Court.

Holding

The Supreme Court affirmed the Court of Appeals’ decision, concluding that issuing the sudden emergency instruction was appropriate. The Court emphasized that an unexpected stoppage caused only by traffic conditions does not warrant a sudden emergency instruction. However, the Court concluded that this case presented a rare exception where the instruction was properly granted because the stoppage was compounded by the bright headlights from the vehicles on the other side of the road, the unexpected collision with the dog, and the absence of brake lights or other warning that Plaintiff’s vehicle had slowed.

Questions about this case can be directed to Cynthia King at (804) 566-3571 or cking@tthlaw.com.