sudden emergency doctrine in Connecticut

7 Connecticut opinions name it 3 courts 1968–2010 0 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

Case	Followed	Cited
Puchalsky v. Rappahahngreen connappct · 2001 · cited in 1 Connecticut opinions naming this issue, 2010–2010 2 sentences 2010See Puchalsky v. Rappahahn, 63 Conn. App. 72, 80 , 774 A.2d 1029 (“Whether a charge on 1he doctrine of sudden emergency was applicable is determined by the claims of proof advanced by the parties. . . . 2010See Puchalsky v. Rappahahn, 63 Conn. App. 72, 80 , 774 A.2d 1029 (“Whether a charge on 1he doctrine of sudden emergency was applicable is determined by the claims of proof advanced by the parties. . . .	1	1
Vachon v. Ivesgreen conn · 1963 · cited in 1 Connecticut opinions naming this issue, 2007–2007 2 sentences 2007See, e.g., Mei v. Alterman Transport Lines, Inc., 159 Conn. 307, 312 , 268 A.2d 639 (1970) (trial court improperly failed to charge on sudden emergency doctrine when plaintiff was injured in motor vehicle accident); Miller v. Porter, 156 Conn. 466,468-70 , 242 A.2d 744 (1968) (charge on sudden emergency doctrine improper when plaintiff offered no proof that defendant had opportunity to choose any course of action that would have prevented defendant from rear-ending plaintiffs car after plaintiff was forced to make emergency stop); Vachon v. Ives, 150 Conn. 452, 455 , 190 A.2d 601 (1963) (“[t]h 2007See, e.g., Mei v. Alterman Transport Lines, Inc., 159 Conn. 307, 312 , 268 A.2d 639 (1970) (trial court improperly failed to charge on sudden emergency doctrine when plaintiff was injured in motor vehicle accident); Miller v. Porter, 156 Conn. 466,468-70 , 242 A.2d 744 (1968) (charge on sudden emergency doctrine improper when plaintiff offered no proof that defendant had opportunity to choose any course of action that would have prevented defendant from rear-ending plaintiffs car after plaintiff was forced to make emergency stop); Vachon v. Ives, 150 Conn. 452, 455 , 190 A.2d 601 (1963) (“[t]h	1	1
Mei v. Alterman Transport Lines, Inc.green conn · 1970 · cited in 1 Connecticut opinions naming this issue, 2007–2007 2 sentences 2007See, e.g., Mei v. Alterman Transport Lines, Inc., 159 Conn. 307, 312 , 268 A.2d 639 (1970) (trial court improperly failed to charge on sudden emergency doctrine when plaintiff was injured in motor vehicle accident); Miller v. Porter, 156 Conn. 466,468-70 , 242 A.2d 744 (1968) (charge on sudden emergency doctrine improper when plaintiff offered no proof that defendant had opportunity to choose any course of action that would have prevented defendant from rear-ending plaintiffs car after plaintiff was forced to make emergency stop); Vachon v. Ives, 150 Conn. 452, 455 , 190 A.2d 601 (1963) (“[t]h 2007See, e.g., Mei v. Alterman Transport Lines, Inc., 159 Conn. 307, 312 , 268 A.2d 639 (1970) (trial court improperly failed to charge on sudden emergency doctrine when plaintiff was injured in motor vehicle accident); Miller v. Porter, 156 Conn. 466,468-70 , 242 A.2d 744 (1968) (charge on sudden emergency doctrine improper when plaintiff offered no proof that defendant had opportunity to choose any course of action that would have prevented defendant from rear-ending plaintiffs car after plaintiff was forced to make emergency stop); Vachon v. Ives, 150 Conn. 452, 455 , 190 A.2d 601 (1963) (“[t]h	1	1
Pareles v. McCarthygreen conn · 1962 · cited in 1 Connecticut opinions naming this issue, 1968–1968 2 sentences 1968See Pareles v. McCarthy, 149 Conn. 238, 244 , 178 A.2d 155 . 1968See Pareles v. McCarthy, 149 Conn. 238, 244 , 178 A.2d 155 .	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (9)

Case	Cited	Years
Miller v. Porter green conn · 1968 2 sentences 2002To assert the doctrine of sudden emergency, it must be proven "(1) that an emergency actually existed, (2) that the perilous situation was not created by the [party asserting the defense], (3) that the [party], confronted with the emergency, chose a course of action which would or might have been taken by a person of reasonable prudence in the same or a similar situation." Ormsby v. Frankel , 54 Conn. App. 98 , 120 , 734 A.2d 575 (1999), aff'd on other grounds, 255 Conn. 670 , 768 A.2d 441 (2001), 1 citing Miller v. Porter , 156 Conn. 466 , 469 , 242 A.2d 744 (1968). 2002To assert the doctrine of sudden emergency, it must be proven "(1) that an emergency actually existed, (2) that the perilous situation was not created by the [party asserting the defense], (3) that the [party], confronted with the emergency, chose a course of action which would or might have been taken by a person of reasonable prudence in the same or a similar situation." Ormsby v. Frankel , 54 Conn. App. 98 , 120 , 734 A.2d 575 (1999), aff'd on other grounds, 255 Conn. 670 , 768 A.2d 441 (2001), 1 citing Miller v. Porter , 156 Conn. 466 , 469 , 242 A.2d 744 (1968).	4	1998–2007
Loulis v. Parrott green conn · 1996 1 sentence 2007The trial court based its denial of the defendant’s motion to set aside the verdict, in part, on this absence of case law supporting such a charge. 11 See Mazuroski v. Hernovich, 42 Conn. App. 574, 577-78 , 680 A.2d 1007 (general verdict rule barred consideration of plaintiffs claim that jury improperly applied contributory negligence, rather than self-defense, to plaintiffs claim of intentional and reckless conduct), cert, denied, 239 Conn. 922 , 682 A.2d 1003 (1996). 12 The plaintiff also argues that the defendant should have invoked the sudden emergency doctrine, which provides that “a defe	1	2007–2007
State v. Colvin green conn · 1996 1 sentence 2007The trial court based its denial of the defendant’s motion to set aside the verdict, in part, on this absence of case law supporting such a charge. 11 See Mazuroski v. Hernovich, 42 Conn. App. 574, 577-78 , 680 A.2d 1007 (general verdict rule barred consideration of plaintiffs claim that jury improperly applied contributory negligence, rather than self-defense, to plaintiffs claim of intentional and reckless conduct), cert, denied, 239 Conn. 922 , 682 A.2d 1003 (1996). 12 The plaintiff also argues that the defendant should have invoked the sudden emergency doctrine, which provides that “a defe	1	2007–2007
Mazuroski v. Hernovich green connappct · 1996 2 sentences 2007The trial court based its denial of the defendant’s motion to set aside the verdict, in part, on this absence of case law supporting such a charge. 11 See Mazuroski v. Hernovich, 42 Conn. App. 574, 577-78 , 680 A.2d 1007 (general verdict rule barred consideration of plaintiffs claim that jury improperly applied contributory negligence, rather than self-defense, to plaintiffs claim of intentional and reckless conduct), cert, denied, 239 Conn. 922 , 682 A.2d 1003 (1996). 12 The plaintiff also argues that the defendant should have invoked the sudden emergency doctrine, which provides that “a defe 2007The trial court based its denial of the defendant’s motion to set aside the verdict, in part, on this absence of case law supporting such a charge. 11 See Mazuroski v. Hernovich, 42 Conn. App. 574, 577-78 , 680 A.2d 1007 (general verdict rule barred consideration of plaintiffs claim that jury improperly applied contributory negligence, rather than self-defense, to plaintiffs claim of intentional and reckless conduct), cert, denied, 239 Conn. 922 , 682 A.2d 1003 (1996). 12 The plaintiff also argues that the defendant should have invoked the sudden emergency doctrine, which provides that “a defe	1	2007–2007
Ormsby v. Frankel green conn · 2001 2 sentences 2002To assert the doctrine of sudden emergency, it must be proven "(1) that an emergency actually existed, (2) that the perilous situation was not created by the [party asserting the defense], (3) that the [party], confronted with the emergency, chose a course of action which would or might have been taken by a person of reasonable prudence in the same or a similar situation." Ormsby v. Frankel , 54 Conn. App. 98 , 120 , 734 A.2d 575 (1999), aff'd on other grounds, 255 Conn. 670 , 768 A.2d 441 (2001), 1 citing Miller v. Porter , 156 Conn. 466 , 469 , 242 A.2d 744 (1968). 2002To assert the doctrine of sudden emergency, it must be proven "(1) that an emergency actually existed, (2) that the perilous situation was not created by the [party asserting the defense], (3) that the [party], confronted with the emergency, chose a course of action which would or might have been taken by a person of reasonable prudence in the same or a similar situation." Ormsby v. Frankel , 54 Conn. App. 98 , 120 , 734 A.2d 575 (1999), aff'd on other grounds, 255 Conn. 670 , 768 A.2d 441 (2001), 1 citing Miller v. Porter , 156 Conn. 466 , 469 , 242 A.2d 744 (1968).	1	2002–2002
Ormsby v. Frankel green connappct · 1999 2 sentences 2002To assert the doctrine of sudden emergency, it must be proven "(1) that an emergency actually existed, (2) that the perilous situation was not created by the [party asserting the defense], (3) that the [party], confronted with the emergency, chose a course of action which would or might have been taken by a person of reasonable prudence in the same or a similar situation." Ormsby v. Frankel , 54 Conn. App. 98 , 120 , 734 A.2d 575 (1999), aff'd on other grounds, 255 Conn. 670 , 768 A.2d 441 (2001), 1 citing Miller v. Porter , 156 Conn. 466 , 469 , 242 A.2d 744 (1968). 2002To assert the doctrine of sudden emergency, it must be proven "(1) that an emergency actually existed, (2) that the perilous situation was not created by the [party asserting the defense], (3) that the [party], confronted with the emergency, chose a course of action which would or might have been taken by a person of reasonable prudence in the same or a similar situation." Ormsby v. Frankel , 54 Conn. App. 98 , 120 , 734 A.2d 575 (1999), aff'd on other grounds, 255 Conn. 670 , 768 A.2d 441 (2001), 1 citing Miller v. Porter , 156 Conn. 466 , 469 , 242 A.2d 744 (1968).	1	2002–2002
Birgel v. Heintz green conn · 1972 2 sentences 1998Birgel v. Heintz , 163 Conn. 23 , 27 , 28 , 301 A.2d 249 . (1972). 1998Birgel v. Heintz , 163 Conn. 23 , 27 , 28 , 301 A.2d 249 . (1972).	1	1998–1998
Stitham v. Leware green conn · 1948 2 sentences 1968Vachon v. Ives, supra; Pareles v. McCarthy, supra; Stitham v. LeWare, 134 Conn. 681, 684 , 60 A.2d 658 . 1968Vachon v. Ives, supra; Pareles v. McCarthy, supra; Stitham v. LeWare, 134 Conn. 681, 684 , 60 A.2d 658 .	1	1968–1968
Foss v. Russo neutral conn · 1968 2 sentences 1968Foss v. Russo, 156 Conn. 230, 232 , 240 A.2d 889 . 1968Foss v. Russo, 156 Conn. 230, 232 , 240 A.2d 889 .	1	1968–1968

Where else courts name it

LA 130 (1934–2026) MI 82 (1957–2026) PA 50 (1932–2023) TX 49 (1970–2025) NC 45 (1956–2023) IN 35 (1972–2019) IA 21 (1962–2018) VA 21 (1933–2024) TN 20 (1963–2024) GA 20 (1965–2026) KY 19 (1953–2022) AL 18 (1972–2011) MS 17 (1961–1994) WV 16 (1948–2018) CA 15 (1953–2025) OH 14 (1993–2020) NE 13 (1953–1993) CO 12 (1976–2014) AZ 11 (1966–2000) ND 9 (1972–2015) AR 9 (1975–1997) NM 9 (1977–1999) MT 9 (1972–2004) FL 8 (1960–2009) CT 7 (1968–2010) RI 6 (1998–2005) WA 6 (1962–2019) SC 6 (1941–2019) VT 5 (1927–2019) NJ 5 (1950–2026) ID 5 (1951–1980) NV 5 (2010–2015) SD 4 (1977–2019) MD 4 (1971–2013) MO 3 (1951–1966) WY 3 (1962–2002) AK 3 (1975–1996) UT 2 (1956–1987) OK 2 (1960–2013) KS 2 (1969–1978) NH 2 (1985–1994) PR 2 (1963–1967) MN 2 (1956–1958)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check