Quick v. Crane
Quick v. Crane, 727 P.2d 1187 (1986)
Summary
In a post-trial appeal, the Supreme Court of Idaho affirmed in part and reversed in part the trial court's decisions regarding a wrongful death action stemming from a multi-vehicle accident. The court held that the trial court erred in denying the defendants' motions for a new trial and remittitur of damages due to insufficient reasoning, while affirming the trial court's rulings on other evidentiary issues and jury instructions. The case was remanded for further proceedings consistent with the opinion.
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Facts
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An accident occurred on Interstate 86 near Pocatello, Idaho on January 3, 1981, due to patches of fog.
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Turner slowed down or stopped in the right lane of traffic after entering a thick patch of fog.
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Fred Arthur Turner was driving a tractor-trailer rig leased by Sigman Meat Company from Rollins Leasing Corporation.
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Numerous cross-claims and counterclaims were asserted, but most were settled before trial.
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A van owned by James Crane collided with the rear of the tractor-trailer rig.
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James Crane, Johnny King, and Rick Quick were injured; Quick subsequently died.
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Lori Quick, Rick Quick's widow, filed a wrongful death action against the parties involved.
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The trial was based on the claims of Crane and King against Turner, Sigman Meat Company, and Rollins Leasing Corporation.
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A white Nova driven by Penny Caldwell then collided with the van, and a pickup driven by Roger Orme collided with the Nova.
Key Holdings
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The trial court erred in denying the defendants' motions for a new trial and remittitur of damages because it did not adequately explain its reasoning for denying the motions. The case is remanded for the trial court to provide its reasoning.
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Defendants' argument fails because they made no objection at the time the alleged improper comments were made, and therefore, the objection is deemed to be waived.
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Although the trial court erred by not having a full evidentiary hearing before the trial pursuant to Iwakiri, the error was harmless because the defendants effectively discredited King's testimony, and the jury verdict indicated they did not believe him anyway.
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The trial court did not err in refusing to disclose the existence of the release agreement or the release itself because the agreement was not a "Mary Carter Agreement," and the trial court did not abuse its discretion by excluding the agreement.
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The trial court did not err in prohibiting the admission of evidence of plaintiffs' non-use of seat belts as evidence of their contributory negligence or comparative fault, nor for the purpose of showing plaintiffs alleged failure to mitigate damages.
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The trial court correctly applied the law on the effect of settlement on the verdict pursuant to I.C. § 6-805, and the amount of Crane's settlements with other parties in the case could be credited against Crane's total verdict whether or not they were found to be liable to Crane.
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The trial court did not err in denying defendants' requested instructions because King and Crane did not request and did not put on evidence in support of future lost earnings or future medical expenses, and no party presented evidence or suggested a method of present value reduction.
Citations
Quick v. Crane, 727 P.2d 1187, 111 Idaho 759, 1986 Ida. LEXIS 532 (1986)
Legal Reasoning
The court addressed several issues raised on appeal, including the denial of post-trial motions, the admissibility of hypnotically-induced testimony, the disclosure of settlement agreements, the seat belt defense, jury instructions on damages, and comments made during closing argument. The court reversed and remanded the denial of the motions for a new trial and remittitur of damages, holding that the trial court must state its reasons for granting or denying such motions. The court affirmed the trial court on all other issues.
Outcome
The order of the trial court denying the defendants' motions for a new trial and remittitur of damages is reversed and remanded for a determination of those motions consistent with this opinion. The trial court is affirmed on all other issues that were raised on appeal. The order of the trial court making such credits is affirmed.
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