Liberty Mutual Insurance v. Bray

Quillian, Judge,

dissenting.

We are confronted in this case with the issue as to whether a mere traffic violation constitutes wilful misconduct within the purview of Code § 114-105. Although several cases have addressed themselves to this broad point, some variance obtains. Compare Aetna Life Ins. Co. v. Carroll, 169 Ga. 333 (150 SE 208); Gooseby v. Pinson Tire Co., 65 Ga. App. 837 (16 SE2d 767); Hall v. Kendall, 81 Ga. App. 592, 595 (59 SE2d 421); Pacific Indem. Ins. Co. v. Eberhardt, 107 Ga. App. 391, 393 (130 SE2d 136); Smith v. Liberty Mut. Ins. Co., 111 Ga. App. 616, 619 (142 SE2d 459), with Reid v. Raper, 86 Ga. App. 277, 279 (71 SE2d 735); Argonaut Ins. Co. v. Almon, 120 Ga. App. 869, 870 (172 SE2d 624); Adams v. U. S. F. & G. Co., 125 Ga. App. 232, 236 (4) (186 SE2d 784).

In Young v. American Ins. Co., 110 Ga. App. 269, 270 (3) (138 SE2d 385), the principle is stated: " 'Under the ruling of the Supreme Court in Aetna Life Ins. Co. v. Carroll, 169 Ga. 333 (150 SE 208) . . . the wilful and conscious doing of an act which is in violation of a penal statute constitutes wilful misconduct and when the violation of such penal statute by the employee is the proximate cause of his injury or death, compensation is barred under the provisions of Code § 114-105.’ Pacific Indem. Ins. Co. v. Eberhardt, 107 Ga. App. 391, 393 (130 SE2d 136).” However, in Argonaut Ins. Co. v. Almon, 120 Ga. App. 869, 870, supra, Chief Judge Bell pointed out: *592"Aetna plainly held that the statutory bar requires conduct of a criminal or quasi-criminal nature; and that negligent conduct, even though grossly so, does not equate with the former. The reversal in Aetna was based solely on the Supreme Court’s honoring the fact-finding board’s determination that the claimant in that case was also guilty of wilful misconduct.” Thus, even though it was argued in the Argonaut Ins. Co. case that the claimant had violated 2 statutory provisions imposing misdemeanor punishment, this court upheld the board’s finding that the claimant’s conduct was negligent only.

Aetna Life Ins. Co. v. Carroll, 169 Ga. 333, supra, equates the term wilful misconduct with "intentional, deliberate action with reckless disregard of consequences ... greater than gross negligence or wanton carelessness.” In my view the claimant’s conduct in this case did not amount to "reckless disregard of consequences.”