(dissenting). In these two separate cases, we are asked to determine whether the city of Detroit Police Department can be held liable for the death of John Rogers and the personal injuries of Deborah and Krystal Ewing. In both cases, police officers attempted to stop a motorist; the motorist fled and subsequently caused an automobile accident, killing or injuring a third-party motorist. In neither case was the police vehicle physically related to the accident other than by the fact that it was pursuing the vehicle that struck the plaintiffs car. Because plaintiffs bring negligence claims against a governmental entity, they must establish both an exception to governmental immunity and each element of a negligence claim in order to prevail. The majority effectively holds that the city of Detroit Police Department may be held liable for the officer’s decision to pursue a fleeing motorist. While I feel compassion for the victims, a principled application of the law of negligence and the law of governmental immunity, as it is currently understood, demonstrates that these plaintiffs are not entitled to recover from this defendant.
Addressing these issues in turn, I do not believe that plaintiffs have pleaded a case that demonstrates an exception to governmental immunity. MCL 691.1407(1); MSA 3.996(107)(1) provides the general *159rule: “Except as otherwise provided in this act, all governmental agencies shall be immune from tort liability in all cases wherein the government agency is engaged in the exercise or discharge of a governmental function.” The Legislature also codified narrow exceptions to this broad grant of immunity. Plaintiffs contend, and the majority agrees, that the motor vehicle exception, MCL 691.1405; MSA 3.996(105), applies to this case. That section states: “Governmental agencies shall be liable for bodily injury and property damage resulting from the negligent operation by any officer, agent, or employee of the governmental agency, of a motor vehicle of which the governmental agency is owner . . . .” Thus, the Legislature decided that governmental entities, such as defendant, could be held liable for the negligent operation of a motor vehicle.
To determine whether that exception applies to these cases, as with all cases addressing governmental immunity, we must start with the fundamental principle recognized by this Court in Ross v Consumers Power Co (On Rehearing), 420 Mich 567, 618; 363 NW2d 641 (1984), i.e., the grant of immunity in § 7 is broad, and the exceptions thereto are to be narrowly construed. Wade v Dep’t of Corrections, 439 Mich 158, 166; 483 NW2d 26 (1992). With this principle foremost in mind, it becomes clear that the decision to pursue a fleeing motorist does not give rise to an exception to governmental immunity. The exception in § 5 applies to the negligent operation of a motor vehicle. A narrow construction of the term “operation of a motor vehicle” would include the manner in which the police vehicle is driven during the pursuit. However, construed narrowly, this exception should not *160encompass the decision to pursue a fleeing motorist, which is separate from the operation of the vehicle itself. Thus, I would find no exception to governmental immunity for a claim based on a police officer’s allegedly negligent decision to stop or pursue a fleeing motorist.
Counter to this argument, the majority would rely on Fiser v City of Ann Arbor, 417 Mich 461; 339 NW2d 413 (1983). In Fiser, police officers conducted a high-speed chase that culminated in the suspect’s vehicle broadsiding the plaintiff’s vehicle, causing the plaintiff severe injuries. This Court, giving a broad reading so as to allow plaintiffs more opportunities to successfully sue municipalities, held that the trial court had erred in granting the defendant’s motion for summary disposition on the basis of governmental immunity because, as noted in Justice Ryan’s concurrence, “[t]he well-pleaded facts of the plaintiff’s complaint establish a jury-submissible question whether Officers Miller and Lunsford operated their police vehicles in a manner which endangered life or property and without due regard for the safety of the plaintiff.” Id. at 477.
Missing from Fiser is the close reasoning that the narrow construction of governmental immunity, which was later adopted by this Court in Ross, precipitates. In the post-Ross era, there is a need to carefully dissect the actions of the defendant so as to give meaning to the rule of. narrow construction. Fiser did not so differentiate, and reasonably so, given the approach to the law of governmental immunity that then pertained. We should do so now, as the currently governing doctrine of governmental immunity calls for, and, thus, distinguish between the deci*161sion to pursue and the manner in which the police car was driven during the chase.
The majority would opine that this view “misapprehends the meaning of Ross” because “[t]he ‘discretionary/ministeriaT test of Ross applied only to the common-law liability of individual employees, not to the statutory liability of governmental agencies.” Ante at 140-141. This distinction is a red herring because the Legislature abolished the ministerial versus discretionary test in 1986. Reardon v Dep’t of Mental Health, 430 Mich 398, 412, n 4; 424 NW2d 248 (1988). The sole issue here is the broadness of governmental immunity and the corresponding narrowness of its exceptions; the ministerial/discretionary side track helps us not at all with that analysis.1
*162The majority further justifies its reliance on Fiser by invoking two notions of legislative acquiescence. First, the majority relies on the garden-variety legislative acquiescence argument, i.e., the Legislature, charged with knowledge of the holding in Fiser, should be seen to have implicitly adopted it by its continued silence on this issue. I believe this argument is flawed. Where, as my analysis above makes clear, Ross ushered in a new era of narrow reading of exceptions and Fiser was a product of the broad-reading era, why would the Legislature have felt a need to do anything about Fiser? After all, Fiser was, as I would understand it, no longer viable in the new era that Ross introduced. Moreover, after Ross was decided, the Legislature, pursuant to 1986 PA 175, “put its imprimatur on the broad scope of immunity as defined in Ross and, by implication, the narrow scope of the exception[s]. ” Reardon v Dep’t of Mental Health, supra, 430 Mich 412. Viewed in this manner, I do not think the Legislature implicitly adopted Fiser at all.
The majority further justifies its reliance on legislative acquiescence on the basis that a bill was introduced that would have changed the result in Fiser and was not adopted. To make this argument, the majority notes that in 1985 House Bill 4003, which would have overruled Fiser, was introduced in the House of Representatives. The bill was not passed through either house and, of course, not signed by the Governor. It is uncontested that after being introduced this bill was referred to the Committee on Judiciary, where it languished and died. That is, this bill, one of 1,866 house bills proposed in the 1985-1986 session, was not, as far as we know, considered, *163debated, or voted upon by the members of the Committee on Judiciary in the House of Representatives or the full House or the Senate. However, for the majority this scanty history is the stuff of which a successful legislative acquiescence argument can be made. I believe it is an irresponsible use of the dubious doctrine of legislative acquiescence to hold that from these few facts it is permissible to conclude that the legislative body as a whole 1) was aware of this Court’s ruling in Fiser, 2) was aware of the substance of the introduced bill, 3) compared the two, 4) after careful consideration made its choice, and 5) signaled the result of all this effort by saying nothing. This is remarkable indeed and is perhaps what former Harvard University Law School Professor Thomas Reed Powell meant when he said in discussing legislative acquiescence arguments of this type:
“[C]ongress has a wonderful power that only judges and lawyers know about. Congress has a power to keep silent. ... Of course when congress keeps silent, it takes an expert to know what it means. But the judges are experts. They say that congress by keeping silent sometimes means that it is keeping silent and sometimes means that it is speaking.” [Report to the Attorney General, Using and Misusing Legislative History: A Re-Evaluation of the Status of Legislative History in Statutory Interpretation, U S Dep’t of Justice, Office of Legal Policy, January 5, 1989, p 110, n 475, citing Powell, The Still Small Voice of the Commerce Clause, in 3 Selected Essays on Constitutional Law 931, 932 (Ass’n of American Law Schools 1938), quoted in Tribe, Toward a syntax of the unsaid: Construing the sounds of congressional and constitutional silence, 57 Ind L J 515, 522 (1982).]
I believe that the majority’s legislative factual history argument, i.e., the recitation of the introduction of *164legislation and its subsequent demise without further consideration by the body, is, as Justice Scalia so aptly said of similar legislative history arguments, “frail substitutes for bicameral vote upon the text of a law and its presentment to the [executive].” Thompson v Thompson, 484 US 174, 192; 108 S Ct 513; 98 L Ed 2d 512 (1988). In fact, if such “history” tells us anything, its meaning eludes me. At the very most, it is a “history” that allows the reader, with equal plausibility, to pose a conclusion of his own that differs from that of the majority.2
The majority’s analysis poses yet a further problem, for it should not be assumed that the Legislature even agrees it has a duty to correct interpretations by the *165courts that it considers erroneous. As Judge Stephen Markman, of our Court of Appeals, insightfully observed on this topic in one of his scholarly writings, “no sensible theory of statutory interpretation would require Congress to devote a substantial portion of its time to extinguishing judicial forest fires.” Markman, On interpretation and non-interpretation, 3 Benchmark 219, 226, n 60 (1987).
As is clear, in my view, this case is an excellent example of the misuse of the doctrine of legislative acquiescence. Indeed, whether it can ever be appropriate to use legislative acquiescence has in the past been the subject of heated debate on this Court. In Autio v Proksch Construction Co, 377 Mich 517, 527; 141 NW2d 81 (1966), Justice Souris described it as “a pernicious evil designed to relieve a court of its duty of self-correction” and indicated that it “has been examined and rejected by this Court before, but its current resurrection demands we perform the task once more lest our silence be construed as signifying its unanswerable validity.” In the course of his discussion, Justice Souris quoted language from Van Dorpel v Haven-Busch Co, 350 Mich 135, 145-146; 85 NW2d 97 (1957), which is worthy of consideration:
Now this beguiling doctrine of legislative assent by silence possesses a certain undeniable logic and charm. Nor are we oblivious to the flattery implicit therein; double flattery, in fact; flattery both to the profound learning and wisdom of the particular supreme court which has spoken, and flattery to a presumably alert and eagerly responsive State legislature. One pictures the legislators of our various States periodically clamoring and elbowing each other in their zeal to get at the pearls of wisdom embalmed in the latest decisions and advance sheets of their respective *166supreme courts — -and thenceforth indicating their unbounded approval by a vast and permanent silence.
Yet there are several dark shadows in this picture. For one, it suggests a legislative passion for reading and heeding the decisions of our supreme courts which we suspect may be scarcely borne out by the facts. For another, pushed too far such a doctrine suggests the interesting proposition that it is the legislatures which have now become the ultimate courts of last resort in our various States; that if they delay long enough to correct our errors those errors thus become both respectable and immutably frozen; and, finally, the larger and more dismal corollary that if enough people persist long enough in ignoring an injustice it thereby becomes just.
In the light of the foregoing discussion, while I do not believe that any form of legislative acquiescence can demonstrate that Fiser is viable after Ross, I would question the use of this analytical tool in this case, where the prerequisites for its use are so entirely lacking.
Beyond the governmental immunity issue, I further disagree that plaintiffs could establish negligence. I disagree that causation can be established in these cases. There are two decisions that the police officers made. The first was the decision to initiate a traffic stop. The second was the decision to pursue once the motorist began to flee. The first decision cannot be the proximate cause of the subsequent accident. Not only does common sense tell us this, but it is also the case that MCL 257.602a; MSA 9.2302(1) mandates that a motorist shall not wilfully fail to obey a police officer’s direction to stop. In light of this statutory obligation on the part of the motorist, and the police officer’s general obligation to apprehend persons breaking the law, what is foreseeable as a matter of *167law for the police officer is that, especially absent some specific knowledge by the officer about this particular driver’s propensity to flee, the officer can legitimately rely on the motorist complying with the statutory obligation to stop. Placek v Sterling Heights, 405 Mich 638, 673, n 18; 275 NW2d 511 (1979), citing Arnold v Krug, 279 Mich 702; 273 NW 322 (1937) (stating that a motorist may assume that other motorists will comply with the rules of the road). Therefore, it cannot be said in this case that it was reasonably foreseeable when the officer attempted to initiate the stop that the motorist would flee in a dangerous manner.
Further, regarding the officer’s second decision, i.e., the decision to pursue once the motorist has commenced to flee, I would hold that plaintiffs cannot establish cause in fact. As is obvious, the motorist had already begun to flee before the decision to pursue was made.3 There is no way, absent sheer speculation, to conclude that the officer’s decision to pursue contributed to the eventual accident. The reason is that at some point the motorist would cease to flee. That could, however, be one hundred feet or one hundred miles later. To decide which is to speculate.
While some may argue that circumstantial evidence can establish cause in fact, “circumstantial proof *168must facilitate reasonable inferences of causation, not mere speculation.” Skinner v Square D Co, 445 Mich 153, 164; 516 NW2d 475 (1994). See also Garabedian v William Beaumont Hosp, 208 Mich App 473; 528 NW2d 809 (1995). To conclude that the police officer’s decision to give pursuit or maintain pursuit was a cause in fact of the accident is nothing more than speculation based on the fact, evident now in hindsight, that the police gave chase and an accident subsequently occurred. This hindsight-based analysis, in a disciplined legal system, logically cannot be the basis for a finding of negligence. Indeed, it is to engage in the logical fallacy of post hoc ergo propter hoc (after this, therefore in consequence of this) that is impermissible. Genesee Merchants Bank & Trust Co v Payne, 381 Mich 234, 248; 161 NW2d 17 (1968) (Kelly, J.); Kaminski v Grand Trunk W R Co, 347 Mich 417; 79 NW2d 899 (1956); Knowles v Knowles, 185 Mich App 497, 499; 462 NW2d 777 (1990). Thus, plaintiffs cannot establish cause in fact, and plaintiffs’ negligence claims should fail on this basis also.
On the basis of my conclusion that governmental immunity should apply in both these cases and that plaintiffs would be unable to prove negligence as a matter of law regarding the decisions to initiate a traffic stop and pursue the fleeing suspects, in Ewing v Detroit, I would reverse the decision of the Court of Appeals and reinstate the order of summary disposition in favor of defendant. In Rogers v Detroit, I would reverse the decision of the Court of Appeals, vacate the judgment for plaintiff, and, as requested by defendants, remand the case to the trial court for a new trial, limiting plaintiff to present only theories regarding the negligent operation of the police vehi*169cle. My resolution of these issues makes it unnecessary to reach the other issues addressed by the majority.
Weaver, J., concurred with Taylor, J.I presume the reference to the discretionary/ministerial test is an attempt to distinguish that part of Boss that stated:
Police officers, especially when faced with a potentially dangerous situation, must be given a wide degree of discretion in determining what type of action will best ensure the safety of the individuals involved and the general public, the cessation of unlawful conduct, and the apprehension of wrongdoers. The determination of what type of action to take, e.g., make an immediate arrest, pursue a suspect, issue a warning, await backup assistance, etc., is a discretionary-decisional act entitled to immunity. Once that decision has been made, however, the execution thereof must be performed in a proper manner, e.g., the arrest must be made without excessive force, the pursuit of the suspect must not be done negligently, the request for assistance must include reasonably accurate information, etc. [420 Mich 659-660.]
While the ministerial/discretional analysis is no longer applicable, this passage demonstrates my fundamental point. For purposes of governmental immunity there is an important difference between determining the appropriate course of action and the manner in which that decision is executed. The latter, in this case the manner in which the police car was driven during the chase, would fall under the motor vehicle exception, while the former, the decision to stop the motorist and pursue, does not.
Commentators have noted that one can posit myriad reasons explaining the Legislature’s failure to correct an erroneous judicial decision, including:
(“Complete disinterest [sic]”; “Belief that other measures have a stronger claim on the limited time and energy of the body”; “Belief that the bill is sound in principle but politically inexpedient to be connected with”; “Unwillingness to have the bill’s sponsors get credit for its enactment”; “Belief that the bill is sound in principle but defective in material particulars”; “Tentative approval, but belief that action should be withheld until the problem can be attacked on a broader front”; “Indecision, with or -without one or another of the foregoing attitudes also”; “Belief that the matter should be left to be handled by the normal processes of judicial development of decisional law, including the overruling of outstanding decisions to the extent that the sound growth of the law requires”; "Positive approval of existing law as expressed in outstanding decisions of the Supreme Court”; “Ditto of the courts of appeals’ decisions also”; “Ditto also of district court decisions”; “Ditto also of one or more varieties of outstanding administrative determinations”; “Etc., etc., etc., etc., etc.”) [Report to the Attorney General, Using and Misusing Legislative History: A Re-evaluation of the Status of Legislative History in Statutory Interpretation, U S Dep’t of Justice, Office of Legal Policy, January 5, 1989, p 113, n 485, citing Hart & Sacks, The Legal Process: Basic Problems in the Making and Application of Law, pp 1395-1396 (tent ed, 1958).]
The facts in Ewing, as described by the majority, highlight this fact. As noted above, once McGuigan was stopped by police officers, he “opened the driver’s door of the pickup truck as if to get out. Suddenly, he slammed the door, drove across oncoming traffic, and fled south on Shaftsbury.” Ante at 132, n 7. Clearly McGuigan’s unlawful and reckless flight was initiated in response to a mere traffic stop and easily could have caused a serious accident at the point when he drove across oncoming traffic, before the police gave chase. This demonstrates that the officer’s decision to pursue did not, in fact, cause the flight that culminated in the accidents at issue here.