"( Id., 30 S.W.2d at pp. 891-892.) In Graves v. Shippey (1959) 209 Ore. 316 [ 337 P.2d 347], a motorcyclist was injured in a collision with a car that emerged out of a grocery store parking lot from behind a parked dairy truck. The court held that "mere blocking of [the plaintiff's] view without more, would not be negligence. "( Id., 337 P.2d at pp. 351-352.)

There is no common law right of contribution among joint tortfeasors. Graves v. Shippey, 215 Or. 616, 618, 337 P.2d 347 (1959); Fidelity Cas. Co. of N.Y. v. Chapman, 167 Or. 661, 664, 120 P.2d 223 (1941). That right was established and is governed by ORS 18.430 to 18.450. Of particular application to this case is ORS 18.440 (1), which provides:

3 Blashfield, Automobile Law and Practice 316, 339-341, § 116. In Graves v. Shippey et al, 215 Or. 616, 625, 300 P.2d 442, 337 P.2d 347 (1959), we held that ORS 483.362 did not apply because the area in question was a residential district. However, we held that the evidence presented a question for the jury as to whether the defendant was guilty of common law negligence for parking in an unsafe place.

The trial court did not err in overruling appellant's motions for directed verdict and judgment notwithstanding verdict. Cardona v. Toczydlowski, 35 Ill. App.2d 11, 180 N.E.2d 709, 713 (1962); Boese v. Love, 300 S.W.2d 453, 458-459 (Mo. 1957); Karlsen v. Jack, 80 Nev. 201, 391 P.2d 319, 321-322 (1964); Graves v. Shippey, 215 Or. 616, 300 P.2d 442, 337 P.2d 347, 351 (1959). All of these cases involved parked vehicles — proximate cause issues.

Its exception did not "particularly" state, as ORCP 59H requires, that the court erred in using the term. In its earlier discussion with the court regarding Graves v. Shippey, 215 Or. 616, 300 P.2d 442, 337 P.2d 347 (1959), defendant did not discuss the propriety of the term "proximate cause." Its reference to Graves did not assist the court, because, in Graves, the court applied the "proximate cause" standard.