## Facts

- A school bus driven by Paul Osteraas (for Orange Glenn School District) and an automobile driven by G. E. Satterlee collided around 8:00 a.m. at the intersection of Citrus Drive (north–south) and Bear Valley Road (east–west) in rural San Diego County.
- Weather was overcast with mist, but visibility was unobstructed for roughly 600 feet along each approach.
- Satterlee drove northbound on Citrus Drive at about 25 mph with his wife as passenger; he saw the bus approaching from his right on Bear Valley Road but continued without changing speed and did not observe the bus again until just before impact.
- Osteraas approached from the east at an estimated 30–35 mph and observed Satterlee’s car from a point well before the intersection.
- Testimony sharply conflicted on vehicle speeds, distances when the drivers first saw each other, and which vehicle entered the intersection first.
- The collision killed Satterlee’s wife and caused Satterlee personal injuries and property damage.
- Satterlee sued the district and the driver for negligence; defendants asserted contributory negligence and sought jury instructions tying liability to statutory intersection right-of-way rules.

## Issues

1. Whether the trial court correctly instructed on the legal effect of California Vehicle Code violations—i.e., whether violations are conclusive negligence or evidence to be weighed with surrounding circumstances and causation.
2. Whether the court erred by refusing defendants’ proposed instructions that would effectively decide liability by which vehicle entered the intersection first or, if simultaneous, which vehicle was on the right.
3. Whether the jury was properly instructed that even a driver favored by statutory right of way must act with ordinary care, and that negligence and contributory negligence remained jury questions on disputed facts.

## Decision

- The California Supreme Court affirmed the plaintiff’s judgment entered on the jury verdict.
- The court held the refusal of defendants’ requested right-of-way instructions was not error because they were incomplete and potentially misleading if presented as mechanically controlling liability.
- The court upheld the challenged instructions, read as a whole, as correctly stating that Vehicle Code violations are significant evidence of negligence but must be evaluated under the reasonable-person standard and proximate cause.
- Given substantial conflicts in the evidence, the jury properly resolved negligence and contributory negligence, and the appellate court would not reweigh those determinations.

## Legal Principles

- Statutory intersection right-of-way provisions do not confer an absolute privilege to proceed without regard to apparent danger; the favored driver must still use ordinary care.
- A Vehicle Code violation in traffic-accident litigation supports an inference of negligence, but the trier of fact may consider surrounding circumstances, excuse, and causation in deciding negligence and liability.
- Jury instructions are reviewed as a whole; refusal of a correct-but-incomplete instruction is proper when it may mislead by suggesting rigid statutory rules displace ordinary-care analysis.
- When evidence about timing, speed, and observation is materially disputed, negligence and contributory negligence are for the jury.

## Conclusion

The court affirmed a plaintiff’s verdict arising from an intersection collision, emphasizing that statutory right of way is qualified by the duty of reasonable care and that Vehicle Code violations are not automatically dispositive of negligence but are evaluated by the jury in light of all circumstances and causation.


Satterlee v. Orange Glenn Sch. Dist. of San Diego Cnty., 29 Cal. 2d 581, 177 P.2d 279 (Cal. 1947)