There are times when the causes of a car accident are difficult to determine. Some accidents may have more than one cause—i.e., one driver is speeding while another is operating a vehicle under the influence of alcohol—and this may lead to a lengthy jury trial to sort out the facts. But there are other cases where a defendant's negligence is obvious based on the available facts. In those cases, an injured plaintiff may be able to get summary judgment on the question of liability, thereby eliminating the need for a trial on that issue.
Man Sues Childhood Friend After Losing Arm in Single-Car Accident
Sometimes trial courts get summary judgment wrong. Here is a recent example from upstate New York. In January 2011, two best friends—the plaintiff and defendant in this case—attended an ice fishing tournament on a lake in Clinton County. The two men stayed about four hours at the tournament, during which time the defendant consumed four beers. After leaving the tournament, the men traveled in separate cars to a nearby bar. En route, the defendant took a prescription painkiller. At the bar, the defendant had another alcoholic drink.
About two hours after arriving at the bar, the defendant and the plaintiff left together in the defendant's van (which was owned by his employer), first to visit the defendant's brother-in-law, and then to go on a service call for the defendant's employer. While navigating a “series of sharp, 90-degree turns,” the defendant lost control of his van, causing it to slide down an embankment, “striking a tree and shattering the passenger-side window.” The plaintiff was pinned between the van and the tree, and subsequently lost his arm.
The plaintiff sued his friend and his employer for negligence. Clinton County Supreme Court denied the plaintiff's motion for summary judgment as to liability, but in January 2016, the Appellate Division, Third Department, reversed. The appeals court said the plaintiff established the defendant’s liability in several ways. First, the driver entered a guilty plea to two violations of New York traffic law in connection with the accident. Second, the driver admitted to consuming multiple drinks and taking medication just before operating his vehicle. Finally, New York State police confirmed the presence of multiple intoxicants in the driver's blood and noted “smelled of alcohol and had bloodshot eyes at the scene.” Accordingly, the Third Division said, it was clear the driver's negligence was the “proximate cause of the accident.” The defendants failed to offer any credible evidence to rebut this conclusion; therefore summary judgment for the plaintiff was appropriate. The case was returned to the Supreme Court for additional proceedings on the issue of damages.