## Facts

- A fatal, single-car crash occurred on May 10, 1984, on Route 24 (Mendham Road) in New Jersey, on a clear night with a dry roadway.
- The vehicle, occupied by Donna Eaton and her mother Sandra Eaton, left the roadway on a leftward, downhill curve, struck a guardrail, became airborne, hit trees, and landed upside down.
- Physical evidence included heavy damage on the passenger side, the passenger door rendered inoperable, Sandra found inside the overturned car, and Donna’s shoe wedged under the brake pedal.
- Donna was outside the car with comparatively minor injuries and repeatedly denied she was driving, asserting her mother swerved to avoid an oncoming vehicle.
- Before her death, Sandra reported that Donna had been driving; an investigating officer concluded Donna was the driver based on the scene evidence.
- Donna was charged with careless driving under N.J.S.A. 39:4-97 and later pleaded guilty.
- Sandra’s estate brought a wrongful-death action alleging Donna’s negligent driving caused Sandra’s fatal injuries.

## Issues

1. Whether the trial court committed reversible (plain) error by failing to instruct the jury on res ipsa loquitur in an unexplained, single-car roadway-departure accident.
2. Whether violation of the careless-driving statute, N.J.S.A. 39:4-97, is negligence per se (as opposed to merely evidence of negligence) and how the jury must be instructed on that effect.
3. Whether a guilty plea to careless driving is admissible in the related civil action and what evidentiary significance it carries.

## Decision

- The Supreme Court of New Jersey affirmed the Appellate Division’s reversal and remand for a new trial.
- The court held that a res ipsa loquitur instruction was required on these facts and that its omission was plain error.
- The court held that a proven violation of N.J.S.A. 39:4-97 is negligence as a matter of law because the statute incorporates the common-law standard of reasonable care; instructing that the violation was only “evidence of negligence” was erroneous.
- The court held Donna’s guilty plea to careless driving was admissible in the civil case as an evidentiary admission of the underlying conduct.
- The combined instructional errors were capable of producing an unjust result, particularly given the verdict finding Donna drove but was not negligent.

## Legal Principles

- Res ipsa loquitur permits a jury to infer negligence when the accident is of a type that ordinarily does not occur absent negligence, the instrumentality was within the defendant’s control, and the plaintiff lacks access to proof of the specific negligent act.
- In an unexplained, single-vehicle departure from the roadway under normal conditions, a res ipsa loquitur charge may be required to allow the jury to draw the permissible inference of negligence.
- When a traffic statute codifies the common-law duty of reasonable care (including N.J.S.A. 39:4-97), proof of its violation establishes breach of duty as negligence as a matter of law; causation and damages remain for the factfinder.
- A guilty plea to a traffic offense is generally admissible in a related civil action as an evidentiary admission; it is probative but not conclusive on all elements of civil liability.
- In civil appeals, unpreserved instructional errors may warrant reversal under the plain-error standard when clearly capable of producing an unjust result.

## Conclusion

The court ordered a new trial because the jury was not instructed on res ipsa loquitur and was incorrectly told that careless driving was only evidence of negligence; it also confirmed that a guilty plea to careless driving is admissible as a civil admission supporting proof of negligent conduct.


Eaton v. Eaton, 119 N.J. 628, 575 A.2d 858 (N.J. 1990)