The appellate court's decision in *Tuttle v. Allstate* underscores the nuanced application of the emergency doctrine. When Brock Gallien collided with Denise Tuttle's overturned vehicle on I-5, the court found that Gallien's lack of time to react negated the use of the emergency instruction. This ruling highlights the critical distinction between instinctive choices and unavoidable accidents in negligence cases.