Bank, 212 Ill. App. 3d 629, 638 (1991); Cunningham v. Miller’s General Insurance Co., 188 Ill. App. 3d 689, 694 (1989); Verson Allsteel Press Co. v. Mackworth Rees, Division of Avis Industrial, Inc., 99 Ill. App. 3d 789 (1981). Likewise, other jurisdictions have defined ‘culpable negligence’ in similar contexts. For example, in Holway v. Ames, 100 Me. 208, 60 A. 897 (1905), the Supreme Judicial Court of Maine defined ‘culpable neglect’ in an analogous context as ‘less than gross carelessness, but more than the failure to use ordinary care.’ Holway, 100 Me. at 211, 60 A. at 898. In other contexts, other courts have defined culpable negligence as something more than mere neglect or more than a mere failure to use ordinary care. E.g., Ross v. Baker, 632 So. 2d 224, 226 (Fla. App. 1994) (<HOLDING>); State v. Giordano, 138 N.H. 90, 95, 635 A.2d
holding prison official must have acted with reckless disregard for the inmates safety holding that negligence does not violate the due process clause but reserving the question whether gross negligence does holding that cjulpable negligence is negligence of a gross and flagrant character which evinces a reckless disregard for the safety of others holding that a adjuster can only incur independent liability when his conduct constitutes gross negligence malice or reckless disregard for the rights of the insured holding that ordinary negligence and gross negligence are not separate causes of action