Finally, Part IV suggests the factors that should be weighed in such a balancing test, … Learned Hand's opinion on gross negligence meaningful distinction (as in a guest statute) Osborne v Montgomery (standard of care) - guy opens a car door to drop something off and biker runs into the door, the standard of the "great mass of mankind" Welcome to 1L torts class! Learned Hand used the following algebraic formula to explain breach of duty: B