## Facts

- Roscoe Hansen owned and drove an automobile on a paved rural highway outside any city or town.
- Manford Scott rode in the front seat as Hansen’s invited guest.
- The automobile struck a cow crossing the roadway, and Scott suffered a fractured right arm.
- The evidence conflicted on whether Scott’s arm was outside the open right-side window at impact.
- Scott sued under Iowa’s guest statute theory, alleging Hansen’s reckless operation caused the collision and injury.
- Scott’s pleaded specifications of recklessness focused on Hansen’s alleged excessive speed and alleged failure to reduce speed when approaching cattle.
- Scott’s proof included testimony containing internal inconsistencies and assertions the court viewed as conflicting with objective physical facts (including claimed distances and vehicle/animal movement compared to claimed braking behavior).

## Issues

1. Whether the trial evidence provided competent, substantial proof that Hansen operated the car recklessly, as required for an invited guest to recover.
2. Whether the trial court erred by denying Hansen’s motion for directed verdict where the plaintiff’s evidence, viewed against physical facts, failed to support the pleaded specifications of recklessness and proximate cause.

## Decision

- The Supreme Court of Iowa reversed the judgment for Scott and remanded with directions to enter a directed verdict for Hansen.
- The court held the record contained no competent evidence from which a reasonable jury could find reckless operation that proximately caused Scott’s injuries.
- The court concluded that, once testimony contrary to physical facts and natural laws was disregarded, the remaining evidence showed at most negligence, which is insufficient under the guest-statute recklessness standard.
- Chief Justice Hamilton dissented.

## Legal Principles

- An invited automobile guest may not recover from the host driver on proof of ordinary negligence; the guest must prove reckless operation as a proximate cause of injury.
- On a motion for directed verdict, evidence is generally viewed in the light most favorable to the nonmovant, but testimony lacking probative value because it is inherently impossible or contradicted by indisputable physical facts may be disregarded.
- A case should not go to the jury when the record lacks substantial, competent evidence on an essential element (here, recklessness), even if some testimony nominally supports that element.

## Conclusion

Because Scott’s own proof did not competently establish that Hansen failed to slow for cattle or continued at a speed and manner evidencing recklessness, and because key testimony was inconsistent with physical facts, the court held the trial court should have directed a verdict for Hansen and reversed the plaintiff’s judgment.


Scott v. Hansen, 289 N.W. 710 (Iowa 1940)