Bedor v. Johnson, 292 P.3d 924

Bedor and Johnson collided after Johnson lost control on a winter road patch; ice patch formed regularly in that road segment.
Johnson knew ice likely present and drove in that area on a regular basis; alcohol and speed evidence contested.
Trial court gave a pattern sudden emergency instruction subpoenaed by Johnson over Bedor’s objection; jury favored Johnson.
Court of Appeals affirmed; Bedor argued instruction was unsupported and prejudicial.
This Court abolished the sudden emergency doctrine, holding it has minimal utility and risks misleading jurors; remand for new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by giving sudden emergency instruction	Bedor argues no competent evidence supported the instruction	Johnson contends evidence showed sudden emergency not created by own fault	Yes, trial court abused discretion by giving instruction
Whether Colorado should retain the sudden emergency doctrine	Bedor seeks abolition to reduce mislead risk	Johnson would benefit from continued rule	Doctrine abolished; not needed in modern negligence law
Whether error was harmless or reversible	Instruction could have affected outcome	Instruction harmless given evidence of negligence	Not harmless; remand for new trial
Impact on standard of care and jury focus	Instruction caused misapplication of standard	Jury correctly understood sudden emergency	Abolition repudiates need for separate instruction

Young v. Clark, 814 P.2d 364 (Colo.1991) (recognizes evolving use of sudden emergency and its explanatory role)
Davis v. Cline, 177 Colo. 204, 493 P.2d 362 (Colo.1972) (supports use of emergency instruction when emergency not of party's making)
Kendrick v. Pippin, 252 P.3d 1052 (Colo.2011) (discusses when competent evidence supports emergency instruction; remand guidance)
Ridley v. Young, 253 P.2d 433 (Colo.1953) (early formation of the sudden emergency doctrine)