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Sorting Out Liability for a Multi-Car Highway Accident


When more than two vehicles are involved in an auto accident, it can be difficult to sort out legal liability. In the case of a chain-reaction accident–e.g., Driver A rear-ends Driver B, which causes Driver B to hit Driver C–the first driver in the chain (Driver A) can be held responsible to damages sustained by the last driver (Driver C), even when there is no direct collision between the two.

Judge Orders New Trial After Incorrectly Instructing the Jury

But proving a chain reaction is often easier said than done. Consider this recent decision by the Iowa Court of Appeals, Coffin v. Doherty, which involves a four-car accident that took place on I-35 in 2014. The plaintiff was at the front of the chain in this case. According to her testimony, she was “braking and slowing to a stop after noticing emergency lights and some brake lights ahead.” At that point, the plaintiff saw another vehicle “approaching quickly from behind.” The plaintiff’s car was then struck by a second vehicle, which caused the plaintiff’s vehicle to spin and get hit by a third vehicle before coming to a stop.

The fourth vehicle in the accident was driven by the defendant. She was not involved in either of the two direct impacts with the plaintiff’s car. Rather, the plaintiff alleged the defendant started a chain reaction by hitting the second vehicle before the collision with the plaintiff’s car. The defendant denied liability, maintaining her collision with the second car did not take place until after it had already struck the plaintiff.

The plaintiff’s case was tried before a jury. At trial, the judge instructed the jury on the “sudden emergency” doctrine. This is a rule that states a party may be excused from liability for an accident if there was an emergency situation caused by “an unforeseen combination of circumstances which calls for immediate action or a sudden or unexpected occasion for action.” For example, in one of the most recent Iowa Supreme Court decisions on the sudden emergency rule, Hagenow v. Schmidt, a driver was excused for causing an accident because she suffered a stroke just before the collision.

The jury in this case returned a verdict for the defendant. The plaintiff then asked for a new trial, arguing the trial judge should not have given the sudden emergency instruction, as no such emergency existed. The judge actually agreed with the plaintiff and ordered a new trial, prompting the defense to appeal to the Court of Appeals.

But the Court of Appeals agreed a new trial was necessary. The sudden emergency rule did not apply to the facts here. Indeed, it made no sense, as the only plausible “sudden emergency” would have been if the second vehicle struck the plaintiff before the defendant hit the second vehicle, which of course was the defense’s theory of the case to begin with. But by giving the sudden emergency instruction at all, the Court of Appeals observed the jury may have been misled or confused.

Speak with a Southeast Iowa Auto Accident Lawyer Today

Determining legal responsibility for a multi-car accident is often quite complicated. That is why if you are involved in such an accident, you should consult a qualified Southeast Iowa personal injury attorney as soon as possible. Contact the Noyes Law Office, P.C., if you need help today.


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