## Facts

- Jonathon Stewart stopped at Martin Motts II’s auto repair shop and offered to help repair a car with an unattached gasoline tank.
- To start and move the car while the tank was unattached, Stewart poured gasoline directly into the carburetor.
- Motts was to turn the ignition key at a specified moment.
- The car backfired, causing an explosion that severely burned Stewart’s upper body.
- Stewart sued Motts for negligence, alleging improper handling of gasoline.
- At trial, Stewart requested a jury instruction stating Motts owed a “high degree of care” because gasoline is a dangerous substance; the trial court refused and instructed the jury on reasonable care under the circumstances.
- The jury returned a verdict for Motts; the Superior Court affirmed.

## Issues

1. Whether Pennsylvania negligence law recognizes a distinct, higher standard of “extraordinary” or “high” care for dangerous instrumentalities such as gasoline, requiring a special jury instruction beyond reasonable care.

## Decision

- The Supreme Court of Pennsylvania affirmed judgment for Motts.
- Pennsylvania recognizes only one standard of care in negligence actions: reasonable care.
- The dangerous character of gasoline affects how reasonable care is applied (care proportional to risk), not the existence of a separate legal standard.
- The trial court did not err in refusing a “high degree of care” instruction where the jury was instructed to apply reasonable care under the circumstances.

## Legal Principles

- Negligence liability is governed by a single duty standard: reasonable care under the circumstances.
- Greater risk requires greater caution, but this is an application of reasonable care, not a separate “extraordinary care” duty.
- Jury instructions should not imply multiple, hierarchically labeled negligence standards when the governing rule is reasonable care calibrated to the danger involved.

## Conclusion

The court held that Pennsylvania does not impose a distinct “high” or “extraordinary” duty for dangerous instrumentalities; the required level of caution is accounted for within the ordinary reasonable-care standard, so a special heightened-care jury charge was properly refused.


Stewart v. Motts, 654 A.2d 535 (Pa. 1995)