Tuesday, September 25, 2012

Lynch v. Rosenthal (1965) (mentally retarded farmhand gets arm stuck in corn husker)


a.       Facts- Π was mentally retarded and Δ was a farmer. Δ “took in” Π after Π had lived at a State Home for mentally retarded children. One day, Δ asked Π to help with corn picking. As Π was corn picking, Π’s arm got caught in the husking machinery, causing serious injury. Π sued Δ for NOT directly warning Π of the danger. Δ argued that Π was contributorily negligent, as a matter of law, for coming too close to the picker.
b.      Procedural History- Trial Ct found for Π, Δ appealed, Ct of appeals affirmed
c.       Issue- Whether Δ owed Π, a “low moron”, the duty to warn Π of the danger involved with corn picking
d.      Holding- Yes, Δ owed Π the duty to warn him of the danger, since Π was a “low moron”
e.       Rule- When faced with a mentally retarded individual, one must exercise care by warning said retard of dangers
f.       Rationale-
                                                              i.      Δ was the one who expressly put Π in that position; had Δ not asked, Π would still have his arm. Therefore, Δ could have at least warned Π of the dangers.
                                                            ii.      While Π was not capable of understanding why there was danger in moving machinery, Π had the capacity to follow and comprehend a warning. Therefore, to NOT warn a retard of danger is to act negligently
g.      Notes-
                                                              i.      Lynch can be squared with Vaughan b/c Menlove was not medically retarded. Vaughan dealt with sane people, Lynch deals with those who are mentally retarded
1.      Mentally challenged people should be held L for their activities, but, if you go too far w/ that, then you are limiting the mental person’s ability to partake in activities normally enjoyed by others
                                                            ii.      Defect must be considered to be “distinct” to afford different treatment

No comments:

Post a Comment