Manning v. Amidon, 649 N.E.2d 1157 (N.Y. 1995)

A plaintiff who knowingly participates in a serious criminal act, such as joyriding, is precluded from recovering damages for injuries sustained as a direct result of that illegal conduct.

Summary

Christina Manning sued Karla Amidon and the vehicle owners for injuries sustained while joyriding in a stolen car. Manning and Amidon, both unlicensed, took the car without permission. Amidon pleaded guilty to theft. Manning sued for negligence after Amidon crashed the car. The court considered whether Manning’s participation in the crime precluded her recovery. The court held that because Manning knowingly participated in a serious illegal act (joyriding), she was barred from recovering damages for injuries directly resulting from that act. This decision reinforces the principle that individuals should not profit from their own wrongdoing.

Facts

Christina Manning and Karla Amidon, both unlicensed drivers, were riding with friends when they spotted a car belonging to the Browns. Amidon, who knew the Browns, found the car keys and started the vehicle. Manning and Amidon took turns driving. While Manning was driving, Amidon mentioned the car was stolen. Later, Manning suggested adjusting the radio to avoid detection. Amidon took her eyes off the road, causing an accident in which Manning was injured. Amidon pleaded guilty to theft of the vehicle.

Procedural History

Manning sued Amidon and the Browns for negligence. The Browns and Amidon moved for summary judgment. The Supreme Court granted the motions, dismissing the complaint. The Appellate Division affirmed. The New York Court of Appeals granted leave to appeal and affirmed the lower court’s decision.

Issue(s)

Whether a plaintiff’s knowing participation in the unauthorized use of a vehicle (joyriding), a criminal act, precludes recovery for injuries sustained as a direct result of that conduct.

Holding

Yes, because Manning’s injuries were a direct result of her knowing participation in a serious violation of the law (joyriding), which is inherently dangerous, public policy precludes her recovery.

Court’s Reasoning

The Court relied on the precedent set in Barker v. Kallash, which established that courts will not entertain a lawsuit if the plaintiff’s conduct constitutes a serious violation of the law and the injuries are a direct result of that violation. The Court emphasized that recovery is denied because public policy generally denies judicial relief to those injured while committing a serious criminal act. Here, Manning knowingly participated in the crime of unauthorized use of a vehicle. She knew the car was stolen, drove it, and suggested actions to conceal their conduct. The accident occurred directly because of this criminal activity. The Court found joyriding to be a serious offense because it involves the use of a dangerous instrument (a car) by inexperienced and unlicensed drivers, posing a threat to themselves and the public. The Court stated, “[R]ecovery is denied, not because plaintiff contributed to [her] injury, but because the public policy of this State generally denies judicial relief to those injured in the course of committing a serious criminal act.” Regarding the Browns, the Court found that they presented sufficient evidence to rebut the presumption of permissive use, and Manning failed to raise a triable issue of fact. The court also noted that Vehicle and Traffic Law § 1210(a) was not violated because the keys were hidden.