Procedure the Trial Court Used to Make Judgment
The trial court relied upon two procedures. First, there was Chouinard v. New Hampshire Speedway where the defendant owned a racetrack and the plaintiff was supposed to attend a race. She purchased a ticket, which was not immediately available.
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Hence, she was to pick it on an appointed date from the racetrack’s booth. After a concerted effort to park her car on the side of the road the booth was located, she could not find a parking spot. She parked on the other side and when crossing the road she was hit by motor vehicle.
The court also relied on the principle that a carrier does not bear responsibility of a passenger once she exits and an innkeeper bears no legal responsibility for a client once she is outside the innkeeper’s premises.
Judgment of the Trial Court
The trial court ruled that the owner of the motel bore no legal responsibility to the client. This is because the motel owner had no control over the premises on which the accident occurred. Additionally, the motel owner had no control over the instrument (motor vehicle), which caused the accident.
Hence, the defendant was not liable for the accident that befell the client. The court observed that the client was not within the care of the motel when he was crossing the road.
Reasoning Of the Trial Court
The trial court heavily depended upon the foresee-ability concept. Depending on a number of cases (Banks v. Hyatt Corp.), Warrington v. Bird, Gunlock v. Gill Hotels Co. Inc., Mulraney v. Auletto’s Catering), the Trial Court reasoned that the occurrence of the accident could not be anticipated.
It was the responsibility of the clients to ensure that they crossed the road safely to the other side of the motel.
Additionally, the court reasoned, it was not the responsibility of the motel owner to operate the movement of vehicles on the highway. Hence, the defendant could not be held liable for any accidents on the highway in as much as they involved her clients.
Argument of the Plaintiff on Appeal
The plaintiff lodged a complaint with the Trial Court on the basis that the defendant was fully aware of the dangers imminent when crossing the highway on Sundays owing to the fact that many Jewish families were clients of the motel and the motel owner had a religious section on the opposite side of the motel where clients were allowed to attend Sunday Mass.
Since many families would cross the road at once after attending mass, it was incumbent upon the innkeeper to take necessary steps to ensure each client crossed safely. It is also crucial to note that the innkeeper operated the motel on both sides of the road, which added onto the fact that it was her responsibility.
Argument of the Defendant on Appeal
On appeal, the defendant held on to the argument she had in the Trial Court. First, she argued that the instrument culpable in the accident was not within her control. Additionally, she argued that the premise on which the accident occurred was not within her control. Second, she argued that she could not foresee the accident.
According to the defendant, the fact that the two factors mentioned above were not within her control added to the fact that she could not foresee the accident. Lastly, the defendant argued that the clients were not within her care once they were outside her premises.
General Rule of Land Ownership
Generally, with respect to landowners, as outlined in Ouellette v. Blanchard, judges have not ruled in any case before that in the event an injury is witnessed at a place far from one’s property, an owner cannot be regarded as liable.
This would greatly inhibit and violate negligence law enshrined in classic cases, such as Palsgraf and Ouellette. Hence, all landowners and occupiers of such land should maintain reasonable care in the operations and maintenance of such property.
The Issue or Legal Question in this Case
The legal question in this case was whether the defendant was liable for the accident that befell the plaintiff’s son. This was considered in light of the question whether the premises and the instrumentality involved in the accident were within the control of the defendant.
Additionally, it was a serious question to determine if the occurrence of the accident was foreseeable from the defendant’s point of view since she operated the motel from either side of the highway and allowed clients to attend Sunday Mass, which would require them to cross the road.
Reasonably Foreseeable Facts
One of the facts was the foresee-ability of the occurrence of the accident from the defendant’s angle. Secondly, it was foreseeable that the Sunday Mass triggered many people crossing the road after its completion. It was also clear that the motel owner subjected the clients to the danger of crossing the road knowing quite well it was her responsibility to protect them from harm.
Important Factual Differences
The factual differences were the gist of the determination of this case in both the Trial Court and opinion of the Appeals Court. First, the defendant operated the motel from either side of the highway. Second, she allowed her clients to attend Sunday Mass on the other side of the road, which essentially required them to cross.
Third, after the Sunday Mass many clients would cross the road at once sometimes with their families. In the Chouinard v. New Hampshire Speedway case the above facts did not exists. For example, the clients were clearly out of the care of a host once outside the premises.
Action Taken by Court Of Appeals
The court of appeal reversed and remanded the trial court’s decision and demanded fresh proceedings consistent with the opinion it offered. The Trial Court ruling, which absolved the defendant from any responsibility, as a matter of law, regarding the accident to the plaintiff, was thereby reversed.
The action was consistent with the facts of the case which were clearly different from the cases relied upon by the Trial Court. It was clear that there was a foreseeable possibility of occurrence of accident because of the crossing of the road on Sundays in droves.
Additionally, the motel was located on either side of the highway. It was an omission by the motel owner not to take necessary precautions to protect her clients from harm.
The plaintiff had a case because the client was crossing the road to access facilities offered by the motel. Hence, the court offered an opinion on which the Trial Court was to rethink its earlier premise.