Control Techniques, Inc. v. Johnson

DICKSON, Justice,

dissenting.

I agree that the adoption of the Indiana Comparative Fault Act did not affect the doctrine of superseding cause, and that the evidence in the record in this case supports giving an instruction on superseding cause. I dissent, however, as to whether the defendant's issue of superseding cause was adequately covered by other instructions, and as to whether the Comparative Fault Act abrogated the common law principle of joint and several liability for joint tortfeasors.

I.

I believe that the majority mistakenly concludes that the trial court's instruction defining proximate cause was adequate to cover the substance of the defendant's tendered but rejected instruction on superseding cause. As acknowledged by the majority, under the facts presented by the record, the defendant was entitled to have the jury informed that an tnforeseeable action by a third party or agency that breaks the causal connection between the defendant's alleged negligence and the plaintiff's injury then becomes the direct cause of the injury. This principle of law was not adequately covered by the trial court's instruction providing the definition of proximate cause, notwithstanding inclusion of the requirement that the cause "must lead in a natural and continuous sequence to the resulting injury." Record at 112. I therefore conclude that the trial court erred in refusing to give the defendant's tendered superseding cause standard pattern jury instruction.

IL.

I also dissent from the majority's unnecessary excursion into the issue of apportionment of liability under the Indiana Comparative Fault Act, and I specifically quarrel with its belief that the Act altered the common law rule of joint and several liability among joint tortfeasors.

The majority asserts that the Comparative Fault Act addressed two major con*111cerns: (1) allocation of liability among multiple tortfeasors and (2) abolition of the doctrine of contributory negligence. To the contrary, in Bowles v. Tatom, 546 N.E.2d 1188 (Ind.1989), this Court declared:

Furthermore, the nature of and procedures established by the Indiana Comparative Fault Act reveal that its primary function is to modify the common law rule of contributory negligence under which a plaintiff only slightly negligent was precluded from recovery of any damages, even as against a relatively highly culpable tortfeasor. In abrogating this harsh rule, the Act allows recovery but reduces such recovery in proportion to any fault of the plaintiff which contributed to the damages.... In furtherance of these objectives, the Act establishes a mechanism by which the factfinder is required to specifically determine the relative degree of the plaintiff's fault with respect to others. This proportional allocation of fault is the means by which the Act's objectives are reached, not the ends to which it aspires.

Id. at 1190 (emphasis added). We did not find the allocation of limited liability among multiple tortfeasors to be a purpose or function of the Act. Significantly, in footnote 1, we stated: "[The Indiana Comparative Fault Act does not expressly prescribe whether the common law principle of joint and several liability is abrogated in cases to which the Act is applicable. This is an unresolved issue which has not yet been addressed by amendatory legislation or by this Court." Id. at n. 1.4

Our rejection of liability allocation as a purpose of the Comparative Fault Act is further demonstrated in Indianapolis P & L v. Snodgrass, in which we quoted with approval the above passage from Bowles and held that the Court of Appeals "[elrro-neously impartled] to the Act the goal of full and complete proportional allocation of fault." Snodgrass, 578 N.E.2d 669, 672 (Ind.1991). Likewise, in Mendenhall v. Skinner and Broadbent Co., we repeated, "The primary objective of the Act was to modify the common law rule of contributory negligence under which a plaintiff was barred from recovery where he was only slightly negligent." 728 N.E.2d 140, 142 (Ind.2000).

The majority states that, under the Act, liability is to be apportioned among tort-feasors in proportion to their percentages of fault as found by the jury. I strongly disagree. As noted in Bowles, the fault determination is necessary to enable the jury to determine a plaintiff's recovery as reflecting the relative degree of plaintiff's fault. But the Act does not require that the resulting fault percentages also be used to limit a joint tortfeasor's liability.

The Comparative Fault Act, adopted in derogation of the common law, must be strictly construed. Snodgrass, 578 N.E.2d at 678. "It is well settled that the legislature does not intend by a statute to make any change in the common law beyond what it declares either in express terms or by unmistakable implication." Id. at 673; see also Durham ex rel. Estate of Wade v. U-Haul Int'l, 745 N.E.2d 755, 767 (Ind.2001); S. Bend Cmty. Sch. Corp. v. Widawski, 622 N.E.2d 160, 162 (Ind.1993); N. Ind. Pub. Serv. Co. v. Citizens Action Coalition of Ind., Inc., 548 N.E.2d 153, 159 (Ind.1989); State Farm Fire & Cas. Co. v. Structo Div., King Seeley Thermos Co., 540 N.E.2d 597, 598 (Ind.1989).

Under common law, joint tortfeasors are subject to both joint and several liability, *112and a tortfeasor may be "liable for the entire loss sustained by the plaintiff, even though [the tortfeasor's] act concurred or combined with that of another wrongdoer to produce the result." W. Paces KEErox ET. AL., ProssEr anp Keprton on tus Law or Torts § 47 at 828 (5th ed.1984); see also Cooper v. Robert Hall Clothes, Inc., 271 Ind. 63, 390 N.E.2d 155, 157 (1979); Hoesel v. Cain, 222 Ind. 330, 345, 53 N.E.2d 165, 171 (Ind.1944); Kiger v. Hazelett, 221 Ind. 575, 576-77, 49 N.E.2d 548, 544 (Ind.1948); Jackson v. Record, 211 Ind. 141, 145, 5 N.E.2d 897, 898-99 (Ind.1987).

The Indiana Comparative Fault Act did not by express terms or unmistakable implication abrogate the common law principle of joint and several liability for joint tortfeasors.5 Furthermore, despite our decisions beginning in 1989 noting this omission, the legislature has not since chosen to enact such abrogation. For these reasons, I dissent to the majority's assertion that the Act requires liability to be apportioned among joint tortfeasors in proportion to their fault.

. Although this Court has never directly confronted and answered whether the Act abrogates joint and several liability, I acknowledge that there exists dicta assuming its abrogation in Cahoon v. Cummings, 734 N.E.2d 535, 541 (Ind.2000).

. In contrast to the Comparative Fault Act, the Indiana Products Liability Act explicitly abrogates the common law principle of joint and several liability in products liability cases. See Ind.Code § 34-20-7-1.