Please discuss IRAC Praesal v. Johnson and Graff v. Beard, and outline the legislative history upon which the courts in these cases relied.
Praesal v. Johnson
This is a case of a partial reversal of the trial court's judgment in favor of all plaintiffs involved. The case revolves around a man named Ronald Peterson, who broadsided another vehicle while experiencing a grand mal seizure. The driver of the other vehicle died from her injuries and her family filed a lawsuit against three of Peterson's doctors and the Sadler Clinic, where he received treatment. The lawsuit was filed on the grounds that the physicians had a duty to warn Peterson not to drive or to report his condition to the authorities.
The trial court determined that the three physicians involved in Peterson's treatment owed no duty to the deceased victim of the car accident or any third parties. The court of appeals upheld this judgment with the exception of the judgment in Dr. Wendenburg's favor. It was determined that, unlike the other physicians and the Sadler Clinic itself, Wendenburg did have a duty to the third party as a result of his prior knowledge of the patient's condition. The reversal of the trial court's ruling in Wendenburg's favor may be in contradiction with common law, which holds that negligence requires the presence of a legal duty, a breach of duty, and resulting damages.
Graff v. Beard
In this case, the court of appeals reversed the trial court's decision to dismiss an injured driver's claims of injury. The appellee injured driver filed a claim against the hosts at a party after a guest attending the party left and drove while intoxicated, resulting in an accident that injured the plaintiff. The trial court determined that the hosts had no legal duty to control the driver's actions simply because they had served alcohol at the party. This is based on a legislative history that holds that one individual has no legal obligation to control another's actions, even if it is feasible. The court of appeals reversed the trial court's dismissal and held that the hosts did have an obligation to the injured appellee.