Evelyn F. Spindle and Robert Lee Spindle, Jr. v. Pearl Reid

Summary

The District of Columbia Court of Appeals held that conflicting evidence regarding an intersectional automobile collision supported the jury's findings on negligence and contributory negligence. It reversed the judgment against the vehicle's registered owner, concluding that she held only naked legal title and was not the statutory owner because her son had exclusive control and use of the vehicle, while affirming the judgment against the son.

Holdings

1. The conflicting testimony concerning the intersectional collision presented questions of fact for the jury on both negligence and contributory negligence, and the verdict would not be disturbed.
2. Registration of legal title in a person's name is not conclusive ownership under the Act. A person who holds only naked legal title and has no immediate right to control or prevent the vehicle's use is not the statutory owner for purposes of liability for the operator's negligence.

Questions Presented

1. Whether the conflicting evidence concerning the conduct of the drivers was sufficient to support the jury's findings concerning negligence and contributory negligence.
2. Whether Evelyn F. Spindle, as the registered legal titleholder, was an owner within the meaning of the District of Columbia Motor Vehicle Safety Responsibility Act and therefore legally responsible for Robert's negligent operation of the automobile.

Disposition

reversed_and_remanded