## Facts

- A single-car accident occurred on an upstate New York highway when a vehicle driven by Charles Williams veered off the road at about 65 mph and overturned in a culvert.
- Plaintiff Gwendolyn Robbins, Williams’s adult daughter and a Jehovah’s Witness, was a passenger and suffered severe orthopedic injuries, including serious damage to her left hip and injury to her right knee.
- Evidence supported a finding that Williams fell asleep at the wheel after a same-day round trip from New York City to Plattsburgh; the jury found him negligent and a proximate cause of the accident.
- Medical experts testified that absent universally accepted surgical procedures, Robbins faced a prognosis likely requiring lifelong wheelchair use due to anticipated necrotic bone development.
- The recommended surgeries required blood transfusions; Robbins refused any procedure involving transfusions because of sincere religious beliefs.
- Defendants argued Robbins failed to mitigate damages by refusing the transfusion-dependent surgeries.
- The trial court instructed the jury to evaluate mitigation using a “reasonable Jehovah’s Witness” standard.
- The jury awarded substantial damages to Robbins; defendants appealed, principally challenging the mitigation instruction.

## Issues

1. Whether mitigation of damages in tort may be judged under a religion-specific “reasonable Jehovah’s Witness” standard rather than the objective “reasonably prudent person” standard when treatment is refused on religious grounds.
2. Whether the Free Exercise Clause requires, or the Establishment Clause permits, a mitigation instruction explicitly keyed to a plaintiff’s denomination.

## Decision

- The Appellate Division reversed the damages judgment and remanded for a new trial on damages; liability was left undisturbed.
- The court held the trial court erred by substituting a sectarian “reasonable Jehovah’s Witness” standard for the neutral civil reasonable-person mitigation standard.
- The court directed that the traditional objective mitigation standard governs, while the plaintiff’s sincere religious beliefs may be considered among the circumstances bearing on reasonableness.

## Legal Principles

- An injured plaintiff must use reasonable and proper efforts to minimize damages; avoidable enhancement of loss is not chargeable to the defendant.
- Mitigation is governed by an objective “reasonably prudent person” standard applied in a secular, generally applicable manner.
- A plaintiff’s sincere religious beliefs may be treated as part of the factual circumstances informing what a reasonable person in that plaintiff’s situation would do, but religion may not be elevated into the rule of decision.
- A jury instruction that frames reasonableness in denominational terms risks unconstitutional entanglement and denominational preference by requiring civil factfinders to assess religious doctrine and “reasonable” adherence.

## Conclusion

The court ordered a new trial on damages because mitigation must be assessed under the objective reasonable-person standard; while the jury may consider a plaintiff’s sincere religious convictions as part of the surrounding circumstances, the law may not adopt a religion-specific “reasonable believer” standard for refusing medical treatment.


Williams v. Bright, 230 A.D.2d 548, 658 N.Y.S.2d 910 (N.Y. App. Div. 1st Dep’t 1997)