Facts
- Deborah Peralta was injured when she was struck by a Washington State Patrol vehicle.
- Before the collision, Peralta had been drinking alcohol and later sought a ride home.
- Peralta called her brother to pick her up; during confusion about where she was standing, she stepped into the roadway to help him see her.
- Peralta mistook an approaching Washington State Patrol vehicle for her brother’s car and stepped into its path, and the vehicle hit her.
- Peralta sued the State of Washington for negligence and sought damages for her injuries.
- The State pleaded Washington’s intoxication-defense statute, RCW 5.40.060, as an affirmative defense.
- During discovery, the State served Peralta with a request for admission asking her to admit that she was “intoxicated,” using language that tracked RCW 5.40.060.
- Peralta responded by admitting the request.
- At trial, the court ruled that Peralta’s admission conclusively established intoxication for purposes of RCW 5.40.060 and instructed the jury on the statute.
- The jury found Peralta’s intoxication was a proximate cause of her injuries, and the trial court dismissed her complaint based on the statutory defense.
- Peralta appealed, arguing that even if she had been drinking, her admission did not conclusively establish the statutory level of intoxication required by RCW 5.40.060.
Issues
- Whether a CR 36 discovery admission, drafted in the statutory language of RCW 5.40.060, can be treated as conclusively establishing the intoxication-defense statute’s requirements so as to support dismissal.
- Whether the trial court erred by giving the admission conclusive effect and instructing the jury as though the statutory intoxication element had been established as a matter of law.
Decision
- The Washington Supreme Court held that Peralta’s discovery admission, phrased in the statute’s terms, could not be treated as conclusively establishing the intoxication-defense statute’s intoxication element.
- The Court ruled that it was error to use the admission to take from the fact finder the contested statutory question whether Peralta’s condition satisfied RCW 5.40.060’s standard.
- The Court reversed the judgment that dismissed Peralta’s claim and remanded for further proceedings consistent with its opinion.
Legal Principles
- Under CR 36, requests for admission may address facts or the application of law to fact, but they are not a proper tool for forcing a party to concede a contested, case-ending legal conclusion stated in statutory terms.
- When an admission tracks a statute’s language rather than specifying concrete facts, it may be too conclusory to conclusively establish the statute’s elements at trial.
- RCW 5.40.060 provides a complete defense only if the defendant proves the statute’s requirements, including the statutory level of intoxication and the required causal and fault findings; those determinations ordinarily turn on fact questions for the jury.
- A trial court errs when it treats a statutory-form admission as automatically satisfying an affirmative defense’s elements and then structures jury instructions and the verdict around that assumed proof.
Conclusion
Peralta v. State held that a discovery admission mirroring RCW 5.40.060’s language could not, by itself, conclusively establish the intoxication-defense statute so as to justify dismissal; the Washington Supreme Court reversed and remanded for further proceedings.