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Driver Slams into Car in Front of Him: Is Not Leaving Enough Stopping Distance a Valid Defense?

Is a driver who rear-ends another vehicle for no other reason than he “didn’t stop quick enough” automatically negligent? The answer is “yes.”

Rear-End Collision

In Smith v. Wells, a plaintiff was driving his Buick down the Pennsylvania Turnpike when he saw traffic braking in front of him. He successfully stopped within the assured clear distance between himself and the car ahead, but the driver of a Jeep Grand Cherokee that was behind him did not.

Instead, the driver of the Jeep Grand Cherokee “jammed on his brakes in a last-ditch effort to avoid impact,” but ultimately hit the Buick and propelled it into the next stopped car. That car was also forced into the car ahead of it, creating a four-car pile-up.

The plaintiff sued the driver of the Jeep Grand Cherokee for a host of physical injuries that he claimed resulted from the accident. At trial the driver’s defense counsel said the collision was his client’s “fault … no question about it.”

The trial, as well as the defense counsel’s arguments, both focused on whether the wreck actually injured the plaintiff. The defense’s theory was that the plaintiff, who had been in three prior automobile accidents, already suffered from ailments he sought to attribute to the instant accident. At no point did defense counsel ask the jury to find that his client had driven carefully.

Before the case was submitted to the jury, the plaintiff’s counsel asked the court for a ruling that the driver of the Jeep Grand Cherokee negligently drove his vehicle so as to breach the standard of care. The court denied counsel’s motion, and the case proceeded to the jury, which was asked to determine whether the driver of the Jeep Grand Cherokee was negligent. The jury could only proceed to the issue of the plaintiff’s damages (if any) if it determined that the driver of the Jeep Grand Cherokee was negligent in causing the accident.

The jury determined that the driver was not negligent.

Following the jury’s ruling, the plaintiff’s counsel argued that a reasonable jury could not reach the verdict that it did and asked the court for a judgment notwithstanding the verdict. The court refused. The court additionally refused to revisit the issue post-trial.

The plaintiff appealed to the Superior Court

On Appeal

In ruling that the plaintiff is entitled to a new trial, the Superior Court relied upon the Pennsylvania statute that governs the speed at which drivers must operate their vehicle:

No person shall drive a vehicle at a speed greater than is reasonable and prudent under the conditions and having regard to the actual and potential hazards then existing, nor at a speed greater than will permit the driver to bring his vehicle to a stop within the assured clear distance ahead.

The court reasoned:

If he had been acting as a reasonable person, [the defendant] would have had sufficient time to brake safely within the assured clear distance ahead, just as [the plaintiff] had done, and just as the driver in front of [the plaintiff] had done, and the driver in front of that driver had done, and so on, and so on up the Turnpike. Thus, as a matter of law, the only person on the Turnpike that day who did not live up to the standards of a reasonably prudent driver was [the defendant], because a reasonably prudent person “invariably looks where he is going, and is careful to examine the immediate foreground before he executes a leap or bound. …”

Conclusion

The takeaway in this case is clear: If you are rear-ended in an auto accident caused because the driver’s speed made it impossible to stop his/her vehicle within the assured clear distance ahead, legal liability on the part of the offending driver is clear-cut.

If you have been injured in an accident, it is important to consult with a personal injury attorney immediately to ensure that your legal rights are protected.