Stewart v. Motts

654 A.2d 535 · Supreme Court of Pennsylvania · 1995

Facts

Plaintiff Jonathon Stewart was injured by an explosion and fire while pouring gasoline into a car's carburetor at Defendant Martin Motts' auto repair shop. The car backfired when Motts turned the ignition, causing Stewart severe burns. A jury found for the defendant, and Stewart appealed, arguing the jury should have been instructed on a 'high degree of care' for dangerous instrumentalities.

Issue

Does Pennsylvania law require a higher standard of 'extraordinary care' for the use of dangerous instrumentalities, such as gasoline, beyond the standard of 'reasonable care,' such that the trial court erred by not giving a specific instruction on 'high degree of care'?

Holding

No. The court affirmed the lower court's decision, holding that Pennsylvania recognizes only one standard of care in negligence actions: 'reasonable care under the circumstances.' The trial court's jury instructions, which stated that the amount of care required varies with the degree of danger, were adequate.

Rule

In Pennsylvania, the sole standard of care in negligence actions, including those involving dangerous instrumentalities, is 'reasonable care under the circumstances.' While the level of care required must be proportionate to the danger involved, this does not establish a separate, higher standard of 'extraordinary care.'

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Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.