Roberts v. Ring
Easy English case explainer — short, clean, classroom style.
Quick Summary
An elderly driver with weak sight and hearing hit a 7-year-old who ran out from behind a buggy. The court held the driver negligent for not stopping in time, and it judged the child’s conduct by the ordinary child standard, not by an adult standard.
Issues
- Was the defendant negligent for failing to stop the car promptly?
- Is a seven-year-old held to the same self-care standard as an adult, or to the ordinary child of his age?
Rules
- A young child is measured by the degree of care commonly used by children of similar age and maturity, not by the adult reasonable person rule.
- Failure to stop a slow car within a short distance can be evidence of negligence.
| Citation | Roberts v. Ring, 173 N.W. 437 (Minn. 1919) |
| Court | Minnesota Supreme Court |
| Area of Law | Torts — Negligence; Contributory Negligence; Standard of Care |
Facts (Timeline)
Driver: Defendant, age 77, with weak sight and hearing, drove on a busy street at ~4–5 mph.
Child: Plaintiff, age 7, ran from behind a buggy across the street and into the path of the car.
Impact: The car struck the boy; he suffered injuries.
Claim: The child’s father sued for negligence to recover damages.
Arguments
Appellant (Plaintiff)
- Defendant failed to stop promptly, even at low speed.
- Child should be judged by a child’s standard, not an adult’s.
Respondent (Defendant)
- Driving slowly and cautiously on a busy street.
- Child darted out suddenly; contributory negligence should bar recovery.
Judgment
The court found the defendant negligent for failing to stop in time. It also held the child was not contributorily negligent because he is measured by the ordinary care of a boy of seven.
Ratio Decidendi
Negligence depends on reasonable care under the circumstances. For children, “reasonable care” means the care of ordinary children of similar age and maturity.
Why It Matters
- Sets the child standard of care in negligence and contributory negligence analysis.
- Shows low speed does not excuse delayed stopping in crowded areas.
- Guides exams on age-based standards and fault allocation.
Key Takeaways
- Child standard: compare to ordinary children of similar age.
- Prompt stop: at 4–5 mph, a car should stop within a few feet.
- Elderly drivers: impairments increase duty to act carefully.
Mnemonic + 3-Step Hook
RING = Reasonable child, Impaired driver, Need to stop fast, Guilt for delay.
- Spot the actors (child vs adult driver).
- Apply correct standard (child of same age).
- Assess stopping response at low speed.
IRAC Outline
Issue
Was the elderly driver negligent, and was the 7-year-old contributorily negligent?
Rule
Adults → reasonable person. Children → ordinary child of similar age/maturity. Failure to stop promptly can be negligence.
Application
At 4–5 mph, car should stop in few feet. Delay shows lack of due care. Child’s actions measured by 7-year-old standard.
Conclusion
Driver negligent; child not contributorily negligent under child standard.
Glossary
- Child Standard of Care
- The caution expected from ordinary children of similar age and maturity.
- Contributory Negligence
- Plaintiff’s own lack of care that helps cause the harm; adjusted here for a child.
- Reasonable Person
- Objective adult standard used to judge negligence for grown persons.
FAQs
Popular & Recent Post
Comment
Nothing for now