A Pennsylvania Court of Common Pleas found that a driver knowingly operating a motor vehicle while fatigued was sufficient to support the award of punitive damages.
In Livingston v. Greyhound Lines, Inc., Anderson was operating a Greyhound bus in the early morning when she rear-ended a tractor trailer. Multiple people were injured and sued Greyhound. The evidence produced during trial revealed Anderson was behind schedule and, thus, drove over the speed limit throughout the night leading up to the morning of the accident. Further evidence produced revealed that Anderson knew she was too tired to drive safely and appreciated the risk to her passengers.
At trial the jury awarded punitive damages. Greyhound appealed and argued the plaintiffs failed to establish Anderson objectively knew her actions were placing the passengers in a high degree of risk or that she consciously elected to disregard such risk. The court found that the evidence indicated driver fatigue was the number one cause of the accident, and there was sufficient evidence for a jury to find that Anderson intentionally disregarded the safety of her passengers, while driving tired. Consequently, the court concluded the award of punitive damages was justified.
Accordingly, this case reveals that operating a motor vehicle while tired, could, under certain circumstances result in the award of punitive damages.
Thanks to Colleen Hayes for her contribution to this post.