--- title: "Hammontree v. Jenner" type: Landmark Case source: https://casebriefly.com/landmark-cases/hammontree-v-jenner --- # Hammontree v. Jenner Hammontree v. Jenner is an important case rejecting the application of strict liability to automobile accidents. The court held that despite the analogy to products liability, the doctrine of strict liability should not be extended to automobile drivers who cause accidents due to sudden medical emergencies. Negligence remains the appropriate standard for automobile accident cases. ## Citation 20 Cal. App. 3d 528, 97 Cal. Rptr. 739 (1971) ## Year 1971 ## Court California Court of Appeal, Second District ## Facts The defendant, Maxine Jenner, was an epileptic who had been seizure-free for fourteen years while taking prescribed medication. While driving, she suffered an unexpected epileptic seizure, lost consciousness, and her car crashed through the storefront of a bicycle shop owned by the plaintiff, causing property damage and personal injuries. Jenner had been cleared to drive by her doctor and had complied with all medical requirements. ## Procedural History The trial court entered judgment for the defendant on the strict liability claim and submitted the negligence claim to the jury, which found for the defendant. The plaintiff appealed, arguing that strict liability should apply. ## Issue Whether a driver who causes an automobile accident due to a sudden, unforeseeable medical emergency should be held strictly liable for the resulting injuries, analogous to strict products liability. ## Holding The court held that strict liability does not apply to automobile accidents caused by sudden medical emergencies. The negligence standard remains the appropriate basis for liability in automobile accident cases. The court declined the plaintiff's invitation to extend the products liability rationale to individual drivers. ## Reasoning The court reasoned that the policy justifications for strict products liability — such as the manufacturer's ability to spread costs, the consumer's inability to inspect products, and the commercial nature of the enterprise — do not apply to individual automobile drivers. Unlike manufacturers, individual drivers cannot spread the cost of liability through pricing and insurance in the same systematic way. The court also noted that adopting strict liability for drivers would create absolute liability whenever an accident occurred, regardless of the driver's exercise of reasonable care. The negligence framework, which considers the driver's knowledge of his condition and compliance with medical advice, better serves the interests of justice. ## Impact Hammontree is significant for establishing a clear boundary around strict liability — it does not extend to individual automobile drivers, even by analogy to products liability. The case reinforced the primacy of negligence in automobile accident cases and is used in law school to illustrate the limits of strict liability doctrine. It also clarified the sudden emergency doctrine as it applies to medical conditions, holding that a driver who experiences a genuinely unforeseeable medical episode is not negligent. ## Key Quotes - The nature of the activity in which defendant was engaged and the relationship of the parties was not such as to warrant the application of the doctrine of strict liability. - The instruction on strict liability should not have been given. Liability of a driver of a motor vehicle for injuries to others has traditionally been based on negligence. ## Related Cases - brown-v-kendall - rylands-v-fletcher - greenman-v-yuba-power-products - butterfield-v-forrester ## Exam Relevance Hammontree appears on exams testing the boundaries of strict liability and when it should versus should not apply. Students may be asked to compare the policy rationale for strict products liability with the reasons it was not extended to automobile drivers, or to analyze the sudden medical emergency defense. ## Study Tips - Use this case to understand the limits of strict liability — it applies to products and abnormally dangerous activities, not to ordinary activities like driving. - Know the policy reasons why strict liability does not apply to individual drivers: inability to spread costs, different relationship than manufacturer-consumer, and potential for absolute liability. - Connect this case to the sudden emergency doctrine and understand when it applies as a defense in negligence cases. - Compare with Rylands v. Fletcher and Greenman to understand where strict liability does and does not apply. ## Doctrine Established Limitation of Strict Liability to Products and Abnormally Dangerous Activities --- Source: [Hammontree v. Jenner — CaseBriefly](https://casebriefly.com/landmark-cases/hammontree-v-jenner)