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Massengale v. Pitts

737 A.2d 1029 (1999)

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Massengale v. Pitts

District of Columbia Court of Appeals
737 A.2d 1029 (1999)

RW

Facts

Minda and Jack Massengale (plaintiffs) sued Marteale Pitts (defendant) for damages; Minda for Pitts’s negligence in causing a car crash, and Jack for loss of consortium resulting from the injuries Minda sustained in the crash. Trial evidence established that Pitts had been negligent and was primarily at fault for the accident but that Minda could have seen and avoided Pitts’s oncoming car. The evidence also established that Minda was driving fast, praying while driving, and not wearing the corrective eyeglasses that Minda’s driver’s license required. The trial court found that Minda’s behavior constituted contributory negligence. The court ruled that the District of Columbia’s contributory-negligence law barred Minda from recovering damages. The court also ruled that the collateral relationship between the negligence and loss-of-consortium claims barred Jack from recovery. The Massengales appealed to the District of Columbia Court of Appeals.

Rule of Law

Issue

Holding and Reasoning (Ruiz, J.)

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