Syracuse Personal Injury Law Blog
In pedestrian accident cases, courts often examine whether environmental conditions played a role in the incident. One significant factor is the visibility of traffic control signals. New York law imposes a nondelegable duty on municipalities to maintain roadways, including ensuring that traffic signals are not obscured by foliage or other obstructions, and if they fail to do so, they may be held accountable, as demonstrated in a recent New York ruling. If you lost a loved one in a pedestrian collision involving dangerous road conditions, it is important to speak with a qualified Syracuse wrongful death attorney about your options for recovery.
History of the Case
It is reported that the plaintiff, acting on behalf of the decedent’s estate, filed a wrongful death action against the defendants, including a municipal entity and a contractor responsible for maintaining trees at the site of a fatal collision. The incident occurred while the decedent was lawfully crossing a street within a marked crosswalk when she was struck and killed by a speeding vehicle.
It is alleged that at the time of the accident, foliage partially obscured the pedestrian signal at the crosswalk where the collision took place. The plaintiff claimed that the obstruction prevented the decedent and other pedestrians from clearly seeing whether it was safe to cross, and further asserted that the obstruction was a contributing factor in the fatal event. The defendants moved for summary judgment, seeking dismissal of the complaint.
It is further reported that in support of their motion, the defendants submitted testimony from a detective with the New York Police Department’s Collision Investigation Squad. The detective had conducted an investigation of the scene and reviewed video and photographic evidence. He testified that the crosswalk signal was partly covered by foliage and that natural lighting conditions at the time, specifically, the angle of the setting sun, further impaired the visibility of the signal. The detective concluded that the obscured signal was a contributing factor in the accident. Thus, the trial court denied the defendants’ motion, prompting the defendants to appeal.
Liability for Pedestrian Accidents
On appeal, the court affirmed the trial court’s denial of summary judgment, allowing the case to proceed. The court began its analysis by reiterating that under New York law, a municipality has a nondelegable duty to keep its roadways in a reasonably safe condition. This duty includes the obligation to ensure that traffic control devices, such as pedestrian signals, are visible and not hidden by overgrown vegetation. Citing established precedent, the court stated that failure to maintain clear visibility of traffic signals may constitute negligent roadway maintenance.
The court determined that the defendants failed to establish their prima facie entitlement to summary judgment. To succeed on such a motion, defendants in a negligence case must show either that they were not negligent or that their alleged negligence did not cause the accident.
In this case, the court found that the defendants did neither. The detective’s expert testimony provided a rational basis for concluding that the obscured signal may have contributed to the decedent’s death. This testimony created a factual issue regarding both negligence and proximate cause, which must be resolved by a jury.
The court rejected the defendants’ argument that photographs and video taken after the accident conclusively demonstrated that the pedestrian signal was visible. The court noted that although the white “walk” symbol was faintly observable through the foliage, these images did not conclusively negate the possibility that the signal was insufficiently visible at the time of the collision, particularly given the testimony about sun glare and partial obstruction. As such, the court held that summary judgment was not appropriate and that the issues of negligence and causation should be evaluated at trial.
Speak With a Knowledgeable Syracuse Personal Injury Attorney
If you lost a loved one in a car accident and believe poor maintenance or visual obstructions contributed to the harm, the experienced Syracuse personal injury attorneys at DeFrancisco & Falgiatano Personal Injury Lawyers can help. We are committed to pursuing justice for families affected by negligence. Call us at 833-200-2000 or contact us online to schedule a free and confidential consultation. We serve clients in Syracuse, Rochester, and throughout Upstate New York.