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New York Court Rejects Motorist’s Request for Summary Judgment Based on Emergency Doctrine in Car Crash Case

The basic question in a Syracuse care accident case is, did the defendant act reasonably under the circumstances? In deciding this issue, the trier of fact is usually given as much information as possible about the circumstances leading up to the collision.

If the defendant was confronted with some type of emergency – such as another car pulling out directly in front of him or her – this fact may be weighed, along with other pertinent information, in deciding whether the defendant was negligent. It is quite possible that a jury could find that, although an emergency did exist, the defendant’s reaction to the situation was not reasonable.

Facts of the Case

In a case arising in the Supreme Court for Monroe County and considered on appeal by the Supreme Court of the State of New York Appellate Division, Fourth Judicial Department, the plaintiff was a woman who was allegedly injured in a car accident. According to the plaintiff’s complaint, the defendant motorist was at fault in causing the accident. The defendant vehicle owner was also named as a party defendant in the lawsuit. The defendants filed a motion asking the trial court to dismiss the complaint against them on the grounds that the facts of the accident should result in the application of the “emergency doctrine,” thus excusing them for liability for the plaintiff’s alleged injuries.

The trial court ruled in the defendants’ favor, thereby granting summary judgment to them and dismissing the plaintiff’s complaint. The plaintiff filed an appeal from the trial court’s order, seeking further review of the issues.

The Reviewing Court’s Opinion

The appellate division reversed the trial court’s order dismissing the plaintiff’s complaint. In reinstating the plaintiff’s complaint and remanding the case to the lower court for further proceedings, the reviewing tribunal summarized the accident by stating that defendant was traveling along a certain road when a white van exited a parkway and made a sudden left-hand turn into the defendant motorist’s path of travel; the defendant hit his brakes and swerved, and, in so doing, drove the wrong way onto the off-ramp, striking the plaintiff’s vehicle in the process.

Although the defendants maintained that they were entitled to summary judgment based upon the emergency doctrine, the court disagreed on appeal. In the court’s view, the issue of whether a qualifying emergency in fact existed – and, if so, whether the defendant motorist’s reactions were reasonable – were questions for the trier of fact. In other words, even if the defendant motorist did encounter a situation that qualified under the law as a “sudden and unexpected emergency,” this alone did not relieve the defendants of liability. Only if the defendants produced evidence sufficient to convince the jury that the defendant motorist’s reaction to the emergency was appropriate under the circumstances would the defendants be excused from liability for the plaintiff’s injuries.

Schedule a Free Consultation with a Syracuse Attorney

Being successful in the pursuit of fair monetary compensation following a car wreck caused by a negligent driver is a multi-step process that begins with a thorough investigation into the accident. If you have been involved in a crash, the helpful Syracuse car accident attorneys of DeFrancisco & Falgiatano, LLP can help. Call us now at 315-479-9000, or use the contact form on this website to contact us about scheduling a consultation to discuss your case.

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