Scott Finnegan was a registered nurse with sleep deprivation and depression for which he sought medical treatment and was prescribed Celexa and Trazodone, both of which warn that people need to be “careful if you drive or do anything that requires you to be awake and alert.”
One week later (11/11/2009 at 4:30 pm), he lost consciousness behind of the wheel, jumped the median on Valley Creek Road in Woodbury, Minnesota and struck another car, driven by Craig Kellogg.
Washington County Judge Mary E. Hannon granted summary judgment for Defendant Finnegan on Kellogg’s negligence claim. She held that Finnegan’s loss of consciousness while driving was “unforeseeable as a matter of law.” The Court of Appeals reversed.
The District Court’s decision, as described above, seems almost comically erroneous. Most of us will readily agree that most people are aware of the risk of falling asleep behind the wheel when suffering from sleep deprivation and taking medicine that specifically cautions about the risk. This proposition seems all the more persuasive when applied to a registered nurse, who presumably has some experience with prescription drugs, the warnings they come with, and the risks of ignoring those warnings.
But, actually, the case is a bit more complicated if one digs deeper. There is evidence in the case that Finnegan did not “fall asleep” at the wheel but, rather, that he had some kind of seizure. This cause of loss of consciousness would not have been foreseeable as a matter of law, the Court of Appeals held, agreeing with the trial court.
The moral of this post is that if a judicial decision seems “off the wall,” look again. Appearances can be deceiving. And skilled advocates can complicate a case that at first seems straightforward on its face.