Task: Text Completion
Input (English): Allwhite directs us to cases where a loss of consciousness by a driver qualified for an instruction of unavoidable accident. For example, in First City Nat’l Bank v. Japhet, 390 S.W.2d 70, 71 (Tex.Civ.App.-Houston 1965, writ dism’d), the defendant suffered a heart attack while driving his vehicle; then, his car crossed the median, crossed the divided road, and drove onto the plaintiffs property, causing certain damages. On appeal, the appellate court found a fact issue had been raised of unavoidable accident and reversed and remanded the trial court’s directed verdict in favor of the plaintiff. Id. at 74. Other jurisdictions have found circumstances similar to this case also warranted an instruction on unavoidable accident. See Houston v. Adams, 239 Ark. 346, 389 S.W.2d 872, 875 (1965) (<HOLDING>); Lutzkovitz v. Murray, 339 A.2d 64, 67 
 Holding statements: (A) holding that such a threat would not supply exceptional circumstances (B) holding in the absence of exceptional circumstances deference should be given to trial court (C) holding that where the board of immigration is permitted to reopen proceedings in exceptional circumstances its decision not to reopen a case is unreviewable because there are no statutory regulatory or caselaw definitions of exceptional circumstances  and  thus no manageable standard to apply on review (D) holding hardship is discovered in the rare case based on exceptional circumstances (E) holding unavoidable accident instruction permitted in most exceptional circumstances such as unanticipated heart attack
Output (English): (E)