In the 2004 case of Morales v. Moore, the Appellate Court explained that "in a case in which a general verdict rule operates, if any ground for the verdict is proper, the verdict must stand; only if every ground is improper does the verdict fall." Following a motor vehicle collision, Debbie Gregory filed a two count complaint alleging that she sustained personal injuries and damages as a result of the negligence of the defendant, John Gregg, in operating his motor vehicle. The defendant denied that he was negligent or that his acts or omissions were the proximate cause of the plaintiff's injuries. By way of a special defense, the defendant alleged that if the plaintiff suffered any injuries and damages, they were the result of her own negligence. A trial ensued. The court entered judgment in accordance with the jury's verdict for the defendant. The plaintiff appealed claiming that the court improperly included a charge on the sudden emergency doctrine in its instructions to the jury. The Appellate Court affirmed the judgment. The general verdict rule precluded review of the plaintiff's claims. The jury rendered a general verdict for the defendant. No interrogatories were submitted to the jury. Therefore, the Appellate Court was unable to determine from the record the basis of the jury's verdict, e.g., whether the jury found that the defendant was not negligent or that he was negligent but that the plaintiff's negligence was greater than his. It could not be determined whether the jury found that either party was confronted with a sudden emergency and, if so, whether his or her response was reasonable.

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