When Can a Judge Deny Punitive Damages in a Truck Accident Trial and Dismiss the Case?
This case arises from a motor vehicle collision where a commercial truck driver for a trucking company was involved in a collision, and the victim asked the court for punitive damages.
One night, while driving for the company, the truck driver “had to stand on [his] brakes with more force than normal” to stop at a red light. He never had any problems with his brakes prior to this. There was no space for him to pull over on the side of the road, and he was close to his destination, so he decided to drive on and check his brakes when got to his “drop.”
The truck driver didn’t get far before he reached another red light—and, this time, he couldn’t stop in time. He was going about 55 miles per hour (which was at or below the speed limit) when the light turned yellow.
He immediately applied his brakes and “should have been able to stop before the red light…if everything was working normal.” But the truck driver said the pedal brake was “stiff,” the engine brake didn’t work at all, and he “wasn’t slowing down much.” He “wasn’t exactly sure if [he] was going to stop” so he turned on his emergency blinkers and “look[ed] for people that may be entering the intersection.” He ultimately went through the red light and crashed into the Plaintiff’s vehicle despite “mak[ing] a left-hand steer to try to avoid the collision.”
The plaintiff sued both the driver and the trucking company for causing the accident. She claimed negligent driving against the truck driver and against the trucking company and sought punitive damages.
Punitive Damages for Negligent Driving
United States District Judge Michael L. Brown noted that the parties agreed the truck driver negligently crashed into the Plaintiff. However, they disputed whether she was entitled to punitive damages for that negligence. The Plaintiff said she was because the truck driver drove “a loaded tractor-trailer with known brake problems at speeds at or above 50 mph through a red traffic light.” The Defendants contended that punitive damages are unwarranted because, although the truck driver’s actions were negligent, they didn’t meet the very high bar for punitive damages as a matter of law. The Court agreed.
Georgia Statutes provide:
Punitive damages may be awarded only in such tort actions in which it is proven by clear and convincing evidence that the defendant’s actions showed willful misconduct, malice, fraud, wantonness, oppression, or that entire want of care which would raise the presumption of conscious indifference to consequences.
Whether a defendant’s conduct is sufficiently aggravating to warrant punitive damages is generally a jury question, Judge Brown explained, but summary judgment (dismissal) is appropriate if the record doesn’t suggest that a plaintiff could carry his burden of proof by showing clear and convincing evidence that the defendant acted with the requisite intent. This is such a case, the judge said.
On the undisputed facts presented here, no reasonable jury could find by clear and convincing evidence that the truck driver engaged in culpable conduct so as to justify an award of punitive damages. He wouldn’t have crashed into the Plaintiff if his brakes were working properly. And he had no reason to believe his brakes were even an issue until the intersection right before he crashed. As such, he drove only a short distance with any knowledge of the mechanical problem that caused the crash. Plus, the mechanical problem didn’t suggest he would be unable to stop the truck as needed to operate it safely, but rather that he would simply have to work harder to do so. Accordingly, Judge Brown held that these undisputed facts reduce his culpability for the Plaintiff’s injuries and precluded punitive damages.
The trucking company’s Motion for Partial Summary Judgment was granted with respect to the Plaintiff’s claim for punitive damages arising from the truck driver’s negligent driving. Dillard v. Smith, 2022 U.S. Dist. LEXIS 83706 (N. Ga. May 9, 2022).
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