## Facts

- Chaffin drove a Ford automobile southbound at night on an 18-foot paved highway in Wilkes County, North Carolina.
- Brame left a Dodge truck parked in the southbound travel lane, blocking the lane, without lights or warning signals.
- As Chaffin approached, an oncoming vehicle driven by Garland displayed glaring, undimmed headlights.
- Chaffin dimmed his own lights, reduced speed, and blinked his lights to signal Garland, but Garland did not dim.
- Chaffin could not see Brame’s unlit truck until after passing Garland’s headlights; at that point the truck was about 30 feet ahead.
- Chaffin attempted to veer left but struck the rear of the truck; his speed at impact did not exceed 20 mph.
- Brame admitted his negligence caused the collision; Chaffin sought property damages to his car.

## Issues

1. Whether Chaffin was contributorily negligent as a matter of law, including under an asserted “stop within range of headlights” rule.
2. Whether the trial court erred by allowing Chaffin to amend the complaint after the verdict and before judgment to conform to the evidence.

## Decision

- The court affirmed judgment for Chaffin and found no error.
- The evidence did not establish contributory negligence as a matter of law; the question was properly submitted to the jury.
- The trial court acted within its discretion by allowing a post-verdict amendment that conformed the pleadings to the proof and did not change the claim.

## Legal Principles

- A person is generally entitled, absent notice to the contrary, to assume others will obey the law and perform their duties; a motorist need not anticipate unlawful hazards such as an unlit vehicle left in a travel lane.
- The “stop within range of headlights” concept is not an absolute rule imposing strict liability; the governing standard is ordinary care under the circumstances.
- Contributory negligence requires plaintiff conduct falling below the standard of self-protective care and contributing legally to the harm; where reasonable minds can differ on plaintiff’s care, the issue is for the jury.
- Trial courts may allow amendments after verdict and before judgment to conform pleadings to the evidence when the amendment does not introduce a new claim or unfairly prejudice the opposing party.

## Conclusion

The court sustained a verdict for the plaintiff, holding that a driver confronted with glare from undimmed oncoming headlights and an unlawfully unlit truck obstructing the lane was not contributorily negligent as a matter of law, and that a post-verdict amendment conforming the complaint to the proof was permissible.


Chaffin v. Brame, 233 N.C. 377, 64 S.E.2d 276 (N.C. 1951)