Hill v. Garner

Background

This case comes from an appeal of an Oregon Supreme Court decision upholding Oregon’s guest-passenger law. The law bars a nonpaying passenger from recovering damages from a vehicle’s owner or driver unless the injury was intentional, caused by gross negligence, or involved intoxication. The appeal asked whether that rule violates the Fourteenth Amendment’s protections for equal treatment or for basic legal fairness.

Reasoning

The Supreme Court dismissed the appeal for lack of a substantial federal question, leaving the Oregon court’s ruling intact. The opinion notes an older Supreme Court case that had upheld a similar guest rule and describes a wide split among state courts—some have struck down guest statutes as unequal, while others have upheld them. The Court has repeatedly declined full review of similar challenges in recent terms, and prior dismissals were treated as rejections of the constitutional attacks.

Real world impact

As a practical matter, this dismissal leaves Oregon’s no-recovery rule in effect, so many nonpaying passengers cannot recover for ordinary negligence in that State. The decision also highlights continuing disagreement among state courts, so whether passengers can sue varies by State. Because a Justice dissented and some state courts continue to invalidate such laws, the question remains contested and could return to higher review.

Dissents or concurrances

Justice White, joined by Justice Brennan, dissented from the dismissal and would have noted probable jurisdiction and scheduled oral argument because of the notable split among state courts.