Davis v. Jenness

McCORMICK, Justice

(concurring specially).

Although I concur in the result I would decide the case on a much narrower ground than the plurality does. The trial court’s finding of the State’s negligence was based on a holding that Trooper Schutt did not *616exercise due care when he failed to review Jenness’ driving record, obtain and study his medical history and give him a driving test before reinstating his driver’s license. I do not believe these omissions constitute substantial evidence of lack of due care. Cf. Wittrup v. Chicago & Northwestern Ry. Co., 226 N.W.2d 822, 824 (Iowa 1975).

The officer knew Jenness’ license had been suspended because of mental illness. He knew the lift notice was issued by the department because the veteran’s hospital had discharged Jenness as “mentally restored”. He also knew the department checked Jenness’ driving record before giving the lift notice. I do not believe a license examiner, in these circumstances, could be said to be required in the exercise of due care to make further inquiry to determine if Jenness, despite the certification of restoration of mental health, was nevertheless incompetent by reason of mental illness to drive an automobile. If, as plaintiff contends, any impairment of Jenness’ driving skills was attributable to his mental illness, the officer had no reason to believe, as a lay person, that any deficiency in Jenness’ physical driving skills existed after he was restored to mental health.

Hindsight, aided by expert medical testimony, shows this reliance was misplaced. It appears Jenness’ mental illness may not be curable, and he may not have been truly “mentally restored” when he was released from the veteran’s hospital. However, I would hold, as a matter of law, the license examiner in this case was not obliged in the exercise of due care to search for evidence to impeach the certification of the hospital.

In cases arising subsequently, the situation may be different. The department of public safety now knows that discharge of a mental patient as having regained “good mental health” under Code § 226.19 may not be wholly accurate, because such discharges may in fact be predicated only on a finding by the hospital that custodial treatment is no longer necessary. Because of this, due care may now require further inquiry.

MASON and RAWLINGS, JJ., join in this special concurrence.