Wilson v. Sibert
535 P.2d 1034 (Alaska 1975)

  • Sibert was waiting in traffic when the car ahead of him began backing up. In order to avoid that car, he backed up also. He ran into the car behind him, which was owned by Wilson. Wilson sued.
    • Sibert claimed that he was reacting on reflex.
  • The Trial Court found for Sibert, Wilson appealed.
    • The jury was given two separate instructions for how to define negligence. They were told the traditional definition about reasonable care, but also told something known as the sudden emergency doctrine.
    • Under the sudden emergency doctrine, Sibert was excused from taking reasonable care to look behind him to see if there was a car there.
  • The Appellate Court affirmed.
    • The Appellate Court found that reasonable care requires “the conduct of a reasonable man of ordinary prudence under the circumstances.”
    • Wilson unsuccessfully argued that since the general definition of reasonable care includes flexibility as to the circumstances, giving the jury a separate instruction about reasonable care during a sudden emergency is inherently prejudicial.