Chain-reaction motor-vehicle accidents or multiple related motor-vehicle accidents raise tricky tort questions regarding proximate cause. The New York Court of Appeals addressed this type of tricky question last week in Tutraini v. County of Suffolk.
In that case, the plaintiff was behind a County of Suffolk police officer (the defendant) on a highway. The police officer defendant suddenly decelerated from approximately 40 mile per hour to 1 to 2 miles per hour. The plaintiff aggressively applied the brakes to her motor-vehicle and was able to stop without hitting the defendant police officer. However, the plaintiff was rear-ended by another defendant seconds later.
A jury found that the defendant officer's reckless conduct and the rear-ending defendant's negligence were each a substantial factor in causing plaintiff’s injuries and apportioned fault at 50% each. The Appellate Division reversed the judgment entered upon the jury’s verdict, holding, as a matter of law, that the defendant officer's conduct was not a proximate cause of the accident because the plaintiff was able to come to a complete stop without hitting the defendant's vehicle.
The Court of Appeals disagreed with the Appellate Division and held that the jury could have rationally found that the officer's conduct was a substantial cause of the collision between the plaintiff and the other defendant even though there was no contact between plaintiff's vehicle and the defendant officer's vehicle. The Court held that the jury could have rationally found that that the officer's conduct " 'set into motion an eminently foreseeable chain of events that resulted in [the] collision' " between the vehicles driven by the plaintiff and the other defendant.
Here's an article in Newsday about the decision.
New York Civil Law 