318 P.3d 1147
Utah Ct. App.2014Background
- In early 2008, Keller and Martinez collided at a signal-controlled intersection in Taylorsville, Utah; Keller was proceeding straight, Martinez was turning left.
- Keller sued Martinez for negligence; Martinez counterclaimed for negligence defenses.
- At trial, Keller testified he stopped at red, then proceeded when green; Martinez testified he stopped at red, then turned left on a green left-turn arrow; Martinez’s wife corroborated the green arrow.
- The district court credited Martinez’s testimony, suggesting Keller ran a red light, and dismissed Keller’s claim for failure to prove Martinez lacked a green light.
- The district court also dismissed Martinez’s counterclaim on the same basis; Martinez did not appeal his dismissal.
- On appeal, Keller argued that Martinez admitted turning left and Keller going straight, which should establish a duty for Martinez; the court disagreed and analyzed applicable statutory provisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which traffic-control provision governs here? | Keller argues section 903 applies universally to left-turners. | Martinez argues section 305 controls at signal-controlled intersections. | Section 305 applies; section 903 does not govern this scenario. |
| Under section 305, did Keller prove Martinez failed to have a green arrow or Keller fail to use the intersection? | Keller claims Martinez owed a duty regardless of Keller’s light color. | Martinez contends he had a green arrow and Keller had to prove otherwise. | Keller failed to prove Martinez lacked a green arrow; Keller must yield even with a green arrow and Keller did not prove breach. |
| Does green-arrow operation require cautious entry and potential mutual breach? | Even with a green arrow, Keller may still have a duty not to impede; color irrelevant argument asserted. | Green-arrow driver has right-of-way but must enter cautiously and yield to lawful traffic. | A green arrow does not authorize careless entry; cautious entry required and mutual breach possible if precautions fail. |
Key Cases Cited
- Webb v. University of Utah, 125 P.3d 906 (Utah 2005) (four elements of negligence: duty, breach, causation, damages)
- Peak Alarm Co. v. Werner, 297 P.3d 592 (Utah 2018) (specific vs general regulatory controls; harmonization of statutes)
- ProMazx Dev. Corp. v. Mattson, 948 P.2d 247 (Utah Ct.App.1997) (view evidence in light favorable to trial court findings on appeal)
- Allen v. Friel, 194 P.3d 908 (Utah 2008) (comparative negligence framework guidance)
- Main St. v. Easy Heat, Inc., 99 P.3d 801 (Utah 2004) (comparative negligence standards and duty analysis)
- French v. Utah Oil Refining Co., 216 P.2d 1002 (Utah 1950) (burden on turning driver when statute prescribes yield of right-of-way)