Mcintyre v. Balentine

McIntyre vs. Balentine is one of the landmark cases in the United States because of its contribution to the adoption of a system of modified comparative fault in Tennessee. Based on this system, a plaintiff may receive compensation for damages where his/her fault is less than the defendant's fault. Notably, the recovery of damages by the plaintiff is lessened to reflect his/her extent of fault.

In situations involving several tortfeasors, a plaintiff's recovery of damages is valid so long as his/her fault is less than the total fault of all tortfeasors ("Comparative Fault & The Empty Chair," n.d.). The lawsuit was determined on the basis of contributory negligence doctrine and comparative negligence. The application of these doctrines as fueled by the need to determine the essential difference in the fault or legal duty between a party or non-party and negligent tortfeasor.

Actions that Contributed to the Suit: Harry Douglas McIntyre, the plaintiff, was involved in a car accident together with Clifford Balentine, the defendant in the early morning of November 2, 1986. The accident, which occurred in the neighborhood of Smith's Truck Stop in Savannah, Tennessee, resulted in severe injuries to McIntyre ("McIntyre v. Balentine," 2013). During the time of the accident, Balentine was traveling south on Highway 69 and McIntyre entered the highway from the parking lot of the truck stop.

A few minutes after his entry to the highway, McIntyre's pickup truck was hit by Balentine's Peterbilt tractor. McIntyre and Balentine had consumed alcohol the evening before the occurrence of the accident. Notably, when McIntyre's blood level was measured after the accident, it was .17% by weight while testimony proposed that Balentine was speeding beyond the established speed limit. Consequently, Harry McIntyre filed a lawsuit against Clifford Balentine and the lessee of the truck i.e. East-West Motor Freight, Inc.

In his defense, Balentine argued that McIntyre was guilty of contributory negligence partly because he was driving while drunk or intoxicated. Lower Court's Rulings: The lawsuit before the lower courts was a negligence action or personal injury action against the defendant. One of the major issues the lower courts had to deal with was the dispute between the parties regarding the chronology of the events that contributed to the accident and incidents preceding it.

Generally, this lawsuit was an ordinary two-party car collision case where one driver sued the other for negligence while the other refuted the negligence claims of the plaintiff by arguing that the plaintiff was contributorially negligent. After the trial, the lower court ruled the case in favor of the defendant since the plaintiff and the defendant were equally at fault in causing the accident ("McIntyre v. Balentine," 2013).

This ruling was informed by the utilization of two basic varying forms of comparative fault by 45 of Tennessee's sister jurisdictions, with the variants commonly known as either pure or modified. In the pure form of comparative fault, the damages of the plaintiff are lessened based on the percentage or degree negligence attributed to him. For instance, if a plaintiff is responsible for 90% of the negligence that causes his/her injuries, he may recover 10% of his/her damages (Day, n.d.).

In contrast, the modified form allows plaintiff to recover damages similar to pure form but only if his/her negligence is not in excess 50% or less than 49% the negligence of the defendant. In the ruling, the judges argued that while there is need to substitute the all-or-nothing rule, they refused to completely abandon the existing fault-based tort system in this jurisdiction.

In essence, the judges did not agree that a party should necessarily be given the right to recover in tort even if they may be responsible for a considerable percentage of fault or negligence. This implies that the lower court judges rejected the pure form of comparative fault in their ruling in favor of the defendant. Furthermore, the jury felt that the 49% rule in the comparative fault system remodeled the severity of the common law but remained compatible with the existing tort system.

However, they acknowledged that the new model of comparative fault systems was simply moving arbitrary contributory negligence to a higher standard. Current Court's Ruling: After the ruling of the trial court in favor of the defendant, the plaintiff brought an appeal against the decision. In the appeal, Harry McIntyre, the plaintiff, argued that the trial court blundered by declining to instruct the jury about the doctrine of comparative negligence.

He also stated that the trial court erred by advising the judges that a blood alcohol level exceeding .10% produces a conjecture of intoxication. The Supreme Court of Tennessee permitted the plaintiff to appeal in order to determine whether a system of comparative fault should be embraced or established in Tennessee. The appeal was also meant to determine the admissibility of criminal conjecture of intoxication as evidence in a civil case.

In its ruling, the Court of Appeals affirmed the decision of the trial court to rule in favor of the defendant. The Court of Appeals' decision was informed by two major arguments including the fact that comparative negligence is not law in Tennessee ("McIntyre v. Balentine," 2013). Secondly, this court held that the criminal presupposition of intoxication is admissible evidence in a civil lawsuit as provided by the 1988 T.C.A. § 55-10-408(b).

Through its ruling, the Court of Appeals basically affirmed in part and rejected in part the judgment of the trial court in favor of the defendant. The court rejected the pure form of comparative fault system by holding that it is not applicable in Tennessee since it is not law. As a result, the court adopted the modified form of comparative fault in attempts not to completely desert the fault-based tort system in the state.

Consequently, as long as the plaintiff's negligence remains less than that of the defendant, the plaintiff may recover ("McIntyre v. Balentine," n.d.). The Court of Appeals also stated that the doctrine of remote and contributory negligence and doctrine of joint and multiple liability are obsolete in order to provide direction to the trial courts. In situations involving multiple tortfeasors, the plaintiffs may recover provided that their fault is minimal as compared to the combined fault of tortfeasors.

The Court of Appeals ruled that the Uniform Contribution Among Tortfeasors Act will no longer be applicable in determining the allotment of liability among or between co-defendants. However, as embedded in Tennessee jurisprudence, there are exceptions.