Hutchins v. Schwartz
Alaska Supreme Court
724 P.2d 1194 (1986)
Charles Hutchins (plaintiff) was in a car accident with Robert Schwartz (defendant) and suffered cuts, bruises, and a broken toe while not wearing a seatbelt; at trial, the judge admitted evidence of Hutchins's failure to wear a seatbelt but later instructed the jury to disregard it. The jury found Hutchins 40% negligent and Schwartz 60% negligent, awarding Hutchins about $1,937 in damages; Hutchins moved for a new trial, arguing the seatbelt evidence should never have been admitted in the first place.
Whether a court may impose a duty on an accident victim to take reasonable precautions, such as wearing a seatbelt, to avoid or reduce the consequences of another driver's foreseeable negligence, and admit evidence of a failure to do so as relevant to comparative fault.