Valdez v. Sams

Plaintiffs alleged in their complaint that they sustained injuries and damages resulting from an automobile collision which was proximately caused by the negligence of defendants. They further alleged that the defendant Sams "willfully, recklessly, carelessly, and negligently drove, or caused to be driven, a motor vehicle into and against the vehicle" in which they were riding, and that said Sams "was guilty of negligence consisting of a reckless or willful disregard of the right or safety of others."