Sibert was waiting in traffic when the car ahead of him
began backing up. In order to avoid that car, he backed up also. He ran
into the car behind him, which was owned by Wilson. Wilson sued.
Sibert claimed that he was reacting on reflex.
The Trial Court found for Sibert, Wilson appealed.
The jury was given two separate instructions for how to
define negligence. They were told the traditional definition
about reasonable care, but also told something known as the sudden
Under the sudden emergency doctrine, Sibert was
excused from taking reasonable care to look behind him to see if
there was a car there.
The Appellate Court affirmed.
The Appellate Court found that reasonable care requires "the conduct of a reasonable
man of ordinary prudence under the circumstances."
Wilson unsuccessfully argued that since the general
definition of reasonable care includes flexibility as to the
circumstances, giving the jury a separate instruction about reasonable
care during a sudden emergency is inherently prejudicial.