Haltom v. Fellows

Plaintiff alleges in his complaint that the automobile, in which he was riding, was caused to go over an embankment on the right side of the road in order to avoid a head-on collision with the automobile owned by defendant, Fellows.

Plaintiff charges all defendants with gross negligence in driving at an excessive speed, in driving on the left-hand side of said highway, in failing to have said automobile under proper control, and in failing to keep a proper lookout.

Plaintiff charges defendant, Fellows, with additional gross carelessness and negligence in being in the act of lighting a cigarette…