Dilliplaine v. Lehigh Valley Trust Co.

Concurring Opinion by

Packel, J.:

Two evidentiary issues are raised as to the application in a tort case of the presumption that a decedent had exercised due care. The appellant contends, first, that the presumption is applicable for the benefit of plaintiffs, and not for the benefit of defendants; and, second, that in any event the presumption is only applicable when the death was caused by the accident. The trial judge had instructed the jury that both the plaintiff, who had no memory of the events immediately preceding and following the accident,1 and the defendant, who died after the accident from unrelated causes, were presumed to have exercised due care.

The well settled presumption of due care in Pennsylvania2 originated in the railroad cases to offset the difficult task of rebutting any inference of contributory negligence which could be drawn solely from the *250occurrence of the accident. The rule has been extended to all kinds of tort actions,3 and has been justified on the basis of the “instinct of self-preservation.” Allison v. Snelling and Snelling, 425 Pa. 519, 525, 229 A. 2d 861, 864 (1967).

In light of the reasoning for the presumption, it would appear to be applicable to a defendant’s defense to a claim of negligence as well as to a plaintiff’s denial of a claim of contributory negligence. Without any discussion of the problem, the courts so held in Balla v. Sladek, 381 Pa. 85, 112 A. 2d 156 (1955), and in Freund v. Huster, 397 Pa. 652, 156 A. 2d 534 (1959) with respect to deceased defendants.

No reported Pennsylvania case appears to have treated the second issue as to the applicability of the presumption to a case in which the death was due to a cause unrelated to the accident in litigation. There are two federal diversity cases, applying Pennsylvania law, which have dealt with the situation, Webb v. Martin, 364 F. 2d 229 (3d Cir. 1966) and Brain v. Elliott-Spicher Motors, Inc., 249 F. Supp. 695 (W.D. Pa. 1966). In both cases the court decided that the presumption of due care was not available to parties who died from unrelated causes. In the Webb case, the decedent had testified in a criminal case, and that evidence was held admissible as an admission. That could have been the basis for denying the presumption. The decision was by three judges but Freedman, J., concurred without any opinion.

Two other jurisdictions have faced the same question and have decided that the presumption is applica*251ble even though the party died from other causes. See Voorheis v. Hawthorne Michaels Co., 151 Cal. App. 2d 688, 312 P. 2d 51 (1957) (California later did away with the presumption of due care completely) and Wells v. Dairyland Mud. Ins. Co., 274 Wis. 505, 80 N.W. 2d 380 (1957). In a third jurisdiction the question was raised and the presumption was held not applicable, but it is not clear whether the holding was based on the fact that the death did not result from the accident or on the fact that there was an eyewitness to the accident. DeBuhr v. Taylor, 232 Iowa 792, 5 N.W. 2d 597 (1942).

The instinct for self-preservation would seem to be equally strong as to a party who survives the accident as to a party who died as a result thereof. In upholding the trial judge’s charge, we are aware that general criticism of the presumption might warrant its restriction.4 However, it is so well recognized in our law, even though its significance is not great,5 that it should not be complicated by a new limitation. It is true that in this case it was admitted that the death was due to an extraneous cause, but if the general rule is to be subjected to the contended limitation, it could create in many cases the problem of determining preliminarily the cause of death.6 Rules of evidence should be couched in terms of practical applicability.

The presumption is applicable when the plaintiff is suffering from loss of memory, Auel v. White, 389 Pa. 208, 132 A. 2d 350 (1957).

There are jurisdictions in which there is no presumption of due care. Generally, jurisdictions which place the burden of proving lack of contributory negligence on the plaintiff do not give a deceased plaintiff the benefit of a presumption of due care. See Siebens v. Konicek, 108 Ill. App. 2d 300, 247 N.E. 2d 453 (1969).

Lear v. Shirk’s Motor Express Corp., 397 Pa. 144, 152 A. 2d 883 (1959) (collision between two tractor-trailers); Morin v. Kreidt, 310 Pa. 90, 164 A. 799 (1933) (pedestrian killed by truck); Ritchey v. Cassone, 296 Pa. 249, 145 A. 822 (1929) (death in a burning building).

See Jurman v. Samuel Braen, Inc., 47 N. J. 586, 222 A. 2d 78 (1966).

“Even though Doctor Heath is dead and ordinarily a presumption might arise that he exercised due care, this presumption is destroyed in the instant case by the testimony adduced by plaintiff. As hold in Watkins v. Prudential Ins. Co., 315 Pa. 497, a presumption such as this is not evidence, and it cannot be weighed as evidence, since it gives way the moment proof to the contrary is presented.” Heath v. Klosterman, 343 Pa. 501, 503-4, 23 A. 2d 209, 210 (1941).

Cf. Goodall v. Hess, 315 Pa. 289, 172 A. 693 (1934).