Syracuse Personal Injury Law Blog
Rear-end motor vehicle collisions remain one of the most common causes of personal injury claims in New York, yet liability disputes frequently arise even when the facts appear straightforward. Courts are often asked to determine whether a trailing driver can overcome the presumption of negligence that applies in rear-end crashes. A recent decision from a New York court reinforces the legal standards governing these cases and clarifies the limited circumstances under which a defendant may avoid summary judgment on liability. If you were injured in a car accident, you should confer with a Syracuse personal injury attorney who can help clarify how these rules apply and what steps are necessary to protect a claim after a serious collision.
History of the Case
It is reported that the plaintiff commenced a personal injury action seeking damages for injuries sustained in a motor vehicle accident. The plaintiff alleged that while operating her vehicle, she was struck from behind by a vehicle operated by the defendant driver and owned by a co-defendant.
Allegedly, following the commencement of the action, the plaintiff moved for summary judgment on the issue of liability. The motion asserted that the plaintiff’s vehicle was stopped at the time of the impact and that the defendant driver failed to maintain a safe distance and speed, resulting in a rear-end collision.
Reportedly, the trial court granted the plaintiff’s motion for summary judgment on liability. The court determined that the evidence established the defendant driver’s negligence as a matter of law. The defendants appealed, contending that issues of fact existed as to how the accident occurred and whether a nonnegligent explanation excused the defendant driver’s conduct.
Liability in Rear-End Collision Cases
On appeal, the court reiterated that a driver approaching another vehicle from the rear has a duty to maintain a reasonably safe distance and rate of speed to avoid a collision. When a stopped or stopping vehicle is struck from behind, the law imposes a prima facie inference of negligence on the operator of the rear vehicle.
Once that presumption is established, the burden shifts to the defendant driver to provide a nonnegligent explanation for the collision. Acceptable explanations may include circumstances such as an unavoidable skid caused by road conditions or other sudden, unexpected events beyond the driver’s control. The court emphasized, however, that a claim that the lead vehicle stopped suddenly, without more, is insufficient to rebut the presumption of negligence.
The court also addressed the defendants’ reliance on the emergency doctrine. That doctrine may excuse otherwise negligent conduct when a driver is confronted with a sudden and unforeseen circumstance that leaves little time for deliberation. The court explained that the doctrine does not apply when the emergency is created or contributed to by the driver seeking its protection. In the context of typical rear-end collisions, courts generally decline to apply the emergency doctrine because drivers are required to anticipate traffic conditions and maintain a safe following distance.
Applying these standards, the court concluded that the plaintiff met her prima facie burden through deposition testimony establishing that her vehicle was fully stopped when it was struck from behind. In opposition, the defendants failed to present evidence raising a triable issue of fact as to any nonnegligent explanation or the applicability of the emergency doctrine. As a result, the court held that the trial court properly granted summary judgment on the issue of liability and affirmed the order in all respects.
Speak with a Dedicated Syracuse Personal Injury Attorney
Rear-end collisions can cause serious and lasting injuries, even when liability seems clear. The experienced Syracuse personal injury attorneys at DeFrancisco & Falgiatano Personal Injury Lawyers represent accident victims throughout Syracuse, Rochester, and across New York State in motor vehicle accident cases. If you were injured in a rear-end crash and have questions about liability or compensation, contact the firm at 833-200-2000 or visit us online to schedule a free and confidential consultation.