Jury instructions are an often overlooked but incredibly important part of the trial process. The instruction that a jury receives helps them understand and evaluate the case, and make a determination about the ultimate issues. Jury instructions can be crafted in a certain way to help tell a party’s story in the jury room, or to include (or omit) certain key details. For all of these reasons, when courts improperly include or exclude certain jury instructions, this is an issue that is often ripe for appeal.
In this Georgia car accident case, A.A. and L.M. were driving in different directions down a two-lane road. As they approached each other, A.A.’s vehicle drifted across the center line and ran into L.M.’s vehicle, causing significant injuries. L.M. sued A.A. for negligence and negligence per se. L.M. established that A.A. had violated Georgia state statutes when his vehicle crossed the center line, which constituted negligence per se. The burden then shifted to A.A. to provide a defense for his actions.
A.A. presented evidence at trial that his steering column was defective and that his auto mechanic had installed the defective steering column a few days earlier. A.A. testified he had no knowledge of the defect until he lost control of his ability to steer on the day of the accident and ran into L.M.’s car. A.A. then asked for a jury instruction, explaining that in order for A.A. to be held liable for the damages incurred as a result of this defective condition, he had to have knowledge of the defective condition. The trial court explained to A.A.’s counsel that he could certainly make this argument to the jury, but the jury instruction would not be included because it was more than what was necessary. The jury ultimately awarded L.M. $30 million in damages. A.A. appealed.
On appeal, the Georgia Court of Appeals noted that under Georgia law, defendants are entitled to jury instructions that explain their defenses to the jury, including a defense of lack of knowledge. The court explained that while the jury instruction must be legally correct, it cannot be excluded simply because the judge may believe it is unnecessary. Here, L.M. had a burden to show that there was negligence per se, which she did. A.A. then had a burden to rebut that presumption of negligence per se by showing a defense for his actions – here, a lack of knowledge and unintentional violations.
Given the importance of this defense, the Court of Appeals concluded that A.A. was entitled to a jury instruction on the issue, since it involved a key legal component of the case. Since these significant issues were not included in the jury instructions that were presented to the jury, the Court of Appeals reluctantly concluded that the only option was for the verdict to be put aside and a new jury trial ordered. Accordingly, the Court of Appeals ordered a new trial.
Given the impact of jury instructions on a jury’s decision making, they are taken very seriously by appellate courts. When a party is denied the opportunity to include an instruction crucial to his or her case, or when a prejudicial or inaccurate instruction is included, this type of issue may ultimately warrant reversal by a court on appeal.
Stephen M. Ozcomert is an experienced litigator who frequently works on car accident cases and understands the importance of jury instructions for both plaintiffs and defendants. Whether you have a simple accident dispute or a complicated multi-party case, he can assist you in crafting a strong theory of your case and with getting the jury instructions necessary to support that theory. Call us today at (404) 370-1000 to schedule your free initial consultation, or you can reach us through our website.
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