Sanders v. Wright

FERREN, Acting Chief Judge,

dissenting:

In this case, the Mitchell-Wright accident, followed five to ten minutes later by Jones’ collision with Sanders, took place on a late evening of a rainy day. Visibility was fair; traffic was heavy. After the Mitchell-Wright accident, Mitchell discovered Wright “slumped over his steering wheel” with head injuries. Ante at [848]. Mitchell and appellant Sanders (Mitchell’s passenger) remained at the scene with the injured man while an off-duty police officer happened by, saw what happened, and left to obtain “police and rescue assistance.” Ante at [848]. As a result of Wright’s negligence, Mitchell’s car remained partly in the road, creating a dangerous obstruction affecting traffic passing the accident scene.1

Under these circumstances, I cannot say Sanders’ failure to leave the scene, or to find a safe haven in the area of the off-ramp, within five to ten minutes of the injury, amounted — as a matter of law — to a break in the chain of causation; Jones’ negligence in striking Mitchell’s car and injuring Sanders did not amount to a superseding cause of Sanders’ injury that altogether exonerated Wright from a jury-triable negligence claim.2

Respectfully, therefore, I dissent.

. The right front end of Mitchell’s Thunderbird was against the right guardrail, but, according to Sanders' testimony "[t]he left rear of the car was in the road”; the tire was not in the road, but the part of the car that “hangs over the tires ... was out in the road.” Sanders further testified at trial that after the accident, the cars that passed by "weren’t in the right lane. They were going around. So, something had to be in the road, or they wouldn’t have gone around us.”

. See, e.g. Morrison v. Frito-Lay, Inc., 546 F.2d 154 (5th Cir.1977) (negligence of truck driver, when he encountered engine trouble, in parking truck with at least two feet protruding onto highway was proximate cause of subsequent accident which occurred when motorist collided with portion of truck protruding onto highway and came to rest in center of highway causing collision between two other automobiles); Hester v. Miller, 41 N.C.App. 509, 255 S.E.2d 318 (1979) (as to rear-end collisions between vehicles slowing or stopping without proper warning signals, and following vehicles, driver of preceding vehicle is not relieved of liability unless second, independent act of negligence could not reasonably have been foreseen; it is not necessary that entire sequence of events be foreseen, but only that some injury would occur); Dickenson v. Tabb, 208 Va. 184, 156 S.E.2d 795 (1967) (where negligence of deceased driver had caused both lanes of highway to be blocked and situation continued to time when another automobile collided with one of the wrecked automobiles, decedent's negligence created situation and started chain of events from which further injury occurred as proximate result, and motorist who negligently struck wrecked vehicle was not superseding *853cause); Johnson v. Heintz, 73 Wis.2d 286, 243 N.W.2d 815 (1976) (jury could have found that first car accident, which occurred during blizzard and left one car protruding onto two-lane highway, was proximate cause of two subsequent accidents in which plaintiff’s car struck preceding car, and another car traveling in opposite direction struck plaintiff's car in an attempt to avoid collision with protruding car from earlier accident).