Williams v. Bright

Gwendolyn Robbins (plaintiff), a Jehovah's Witness, was injured when a car driven by her father overturned; she refused recommended surgeries because they would require blood transfusions barred by her faith. She sued the vehicle's lessor, Bright (defendant), who conceded liability but contested her failure to mitigate damages. Over Bright's objection, the trial court instructed the jury using a reasonable Jehovah's Witness standard rather than the ordinary reasonable-person standard; the jury found for Robbins, and Bright appealed.

Whether a jury may consider evidence of a plaintiff's religious beliefs in deciding whether the plaintiff acted reasonably in mitigating damages, without applying a special standard that defers entirely to those beliefs.