Syracuse Personal Injury Law Blog
Rear-end collisions are among the most straightforward traffic cases in New York law, as it is often presumed that the rear driver is at fault. Nonetheless, such cases can still be complicated, as demonstrated in a recent New York opinion issued in a case involving a chain-reaction collision. If you were hurt in a multi-vehicle accident, you may be owed damages, and you should speak to a Syracuse car accident attorney as soon as possible.
History of the Case
It is reported that the plaintiff was involved in a chain-reaction collision during morning rush hour while driving in stop-and-go traffic on a wet and drizzly roadway. According to the plaintiff, her vehicle was fully stopped when it was struck from behind after the defendant, the rear-most driver in the chain, collided with a middle vehicle, which was then pushed into the plaintiff’s car. The plaintiff brought a personal injury lawsuit against the defendant, alleging that the defendant’s negligent operation of her vehicle caused the crash and her resulting injuries.
It is alleged that at trial, the plaintiff rested her case before the defendant had presented any evidence and then moved for a directed verdict on the issue of liability. The trial court denied the motion as premature. The jury ultimately ruled in favor of the defendant. The plaintiff then filed a post-trial motion under CPLR 4404 seeking judgment notwithstanding the verdict or, in the alternative, a new trial. The trial court denied the motion, and the plaintiff appealed.
It is further reported that the evidence introduced at trial included testimony from the plaintiff, the defendant, and the driver of the middle vehicle. The plaintiff testified that she was at a complete stop when the collision occurred. The middle driver claimed he did not initially hit the plaintiff’s vehicle but was instead propelled forward only after being struck by the defendant’s car. The defendant testified that she attempted to swerve to avoid impact but was unsuccessful and believed the middle vehicle may have hit the plaintiff first. The jury nonetheless found no negligence on the part of the defendant. The plaintiff appealed.
Liability in Chain Reaction Collisions
On appeal, the court reversed the trial court’s judgment, concluding that the jury’s finding in favor of the defendant could not be sustained based on the record. The court began by reaffirming the legal principle that in rear-end collisions, the driver of the rear-most vehicle is presumed to be negligent. This presumption creates a prima facie case of liability, shifting the burden to the rear driver to provide a non-negligent explanation for the accident.
Citing long-standing precedent, the court explained that a sudden stop by the lead vehicle in stop-and-go traffic does not constitute a legally sufficient, non-negligent explanation. The law anticipates that in such conditions, drivers must maintain a safe following distance and be prepared for frequent stops. The defendant’s assertion that the middle vehicle stopped suddenly was therefore inadequate to rebut the presumption of negligence.
The court also noted that the plaintiff’s motion for a directed verdict had been properly denied because it was made prematurely, before the defendant had an opportunity to present her case. However, the court agreed with the plaintiff that her post-trial motion for judgment notwithstanding the verdict should have been granted in part. Given the uncontroverted evidence and the absence of any credible non-negligent explanation by the defendant, no rational jury could have found that the defendant was not negligent.
As a result, the appellate court set aside the verdict, reinstated the complaint against the defendant, and remitted the matter for a new trial limited to the issues of proximate cause and, if warranted, damages.
Meet with a Capable Syracuse Personal Injury Attorney
Rear-end collisions may seem simple, but legal disputes over fault and causation can complicate even the clearest cases. If you were injured in a car accident and believe another driver’s negligence is to blame, the capable Syracuse personal injury attorneys at DeFrancisco & Falgiatano Personal Injury Lawyers are here to help. Contact us at 833-200-2000 or reach out online to schedule a free and confidential consultation. We serve clients in Syracuse, Rochester, and throughout Upstate New York.