Summary
The Washington Supreme Court held that whether the defendant exercised reasonable care in making a left turn was properly for the jury to decide based on conflicting testimony from the two drivers. The court reversed the Court of Appeals and reinstated the jury’s verdict for the defendant, emphasizing that appellate courts may not substitute their credibility determinations for those of the jury.
Topics
Practice areas
Questions Presented
- Whether Antonellis was negligent as a matter of law despite conflicting testimony about the location and visibility of Morse’s vehicle.
- Whether the Court of Appeals improperly substituted its assessment of the evidence and witness credibility for the jury’s determination.
Holdings
- Antonellis was not negligent as a matter of law because the conflicting testimony permitted a reasonable jury to find that she acted reasonably when beginning her left turn.
- The appellate court could not substitute its judgment for the jury’s credibility determinations; credibility questions belong to the trier of fact and cannot be reviewed on appeal.
Key quotations
“there is no substantial evidence or reasonable inference to sustain a verdict for the nonmoving party.” (149 Wash. 2d at 574)
“Juries decide credibility, not appellate courts.” (149 Wash. 2d at 575)
Factual background
Antonellis stopped in the inside lane of a four-lane street intending to turn left. A pickup truck stopped opposite her was also signaling to turn left, and Antonellis testified that she checked the opposing inside lane, saw no traffic, and slowly began her turn. Morse was traveling westbound and collided with Antonellis after Antonellis crossed into the opposing curb lane; the parties gave conflicting accounts of Morse’s lane and whether she was visible beyond the pickup truck.
Procedural history
Morse sued Antonellis for negligence arising from a left-turn collision. The jury found that Antonellis did not negligently cause the accident, and the superior court denied Morse’s motion for judgment notwithstanding the verdict. The Court of Appeals reversed, but the Washington Supreme Court concluded that the conflicting testimony presented credibility and reasonableness questions for the jury.
Remand instructions
The jury’s verdict in favor of Antonellis was reinstated.