In a recent decision from Florida’s Fifth District Court of Appeal, Manfre v. Shinkle, the court examined whether a jury correctly found that the defendant, a local sheriff, was liable for injuries arising from a motor vehicle accident. Although the accident at issue occurred at night on an unlit, rural road, the lack of light only played a marginal role. Instead, the crash was principally caused by the plaintiff’s collision with a dead horse, which the plaintiff claimed was in her path because of a local deputy’s negligent investigation of a report of roaming animals.
The accident at the heart of Manfre occurred shortly before sunrise on a dark road in rural Flagler County. The plaintiff was traveling at about 45 miles per hour when her vehicle struck a dead horse and flipped. As a result of the accident, the plaintiff suffered a variety of physical injuries. About an hour and a half before this accident, the county’s Sheriff’s Office received a call that reported two horses were roaming on the side of the road where the accident occurred. A deputy responded to the scene, where he saw the horses returning to the pasture. Evidence presented at trial indicated that the horses may have been spooked by the sheriff’s headlights. Satisfied that the horses’ return to the pasture settled the issue, the deputy cleared the call and left the scene without either ensuring that the horses were now safely enclosed or contacting the property owner. Following the deputy’s departure, at least one of the horses returned to the road, where it was struck by a vehicle and killed. It was the dead horse with which the plaintiff’s vehicle collided.