Under New York law, drivers must maintain a safe following distance and drive at a reasonable speed to avoid accidents. A rear-end collision is often considered a clear-cut example of negligence on the part of the following driver. However, establishing liability in such cases still requires adequate evidence. A recent New York case involving a rear-end collision highlights the challenges plaintiffs may face in pursuing summary judgment when evidence is deemed insufficient. If you were injured in a rear-end collision, it is wise to contact a Syracuse personal injury attorney promptly to explore your options.
History of the Case
It is alleged that the plaintiff filed a lawsuit against the defendants, alleging that one of the defendants negligently struck her car from behind on October 21, 2022, while she was stopped for traffic at an intersection in Brooklyn, New York. The plaintiff claimed serious injuries as a result of the collision.
Reportedly, the plaintiff filed a motion for summary judgment on the issue of liability. She also sought to dismiss the defendants’ affirmative defense of comparative negligence. In support of her motion, the plaintiff submitted an affidavit and a certified police report. The affidavit stated that she was stopped for traffic when the defendants’ vehicle suddenly struck her car in the rear. The police report corroborated that the defendant driver’s vehicle rear-ended the plaintiff’s vehicle but did not provide additional details regarding the circumstances of the collision.
The defendants contested the plaintiff’s motion, arguing that the plaintiff’s evidence was insufficient to establish a prima facie case of liability or eliminate all issues of comparative negligence.
Grounds for Denying Summary Judgment in Car Accident Cases
The court evaluated whether the plaintiff’s affidavit and supporting evidence were sufficient to establish the defendants’ liability and eliminate any triable issues of fact. It noted that under New York law, a driver of a vehicle approaching another vehicle from behind is required to maintain a safe distance and avoid collisions. A rear-end collision creates a presumption of negligence by the following driver, which can only be rebutted with a non-negligent explanation, such as an unexpected stop by the lead vehicle.
The court held that the plaintiff’s affidavit was overly brief and lacked critical details. Specifically, it failed to address key factors such as the prevailing traffic and weather conditions, the reason for the plaintiff’s stop, and whether the plaintiff’s brake lights were operational at the time of the collision. Additionally, the affidavit did not provide sufficient detail regarding how the plaintiff identified the defendants’ vehicle as the one that struck her car.
Further, the court found that the affidavit and police report together failed to rule out the possibility of comparative negligence on the plaintiff’s part. For instance, the plaintiff did not explain whether her stop was sudden or gradual, nor did she clarify how long she had been stopped before the collision. The court emphasized that even in rear-end collisions, the issue of comparative negligence may remain if the lead driver’s actions contributed to the accident.
As such, the court denied the plaintiff’s motion for summary judgment on both liability and the issue of comparative negligence, ruling that material issues of fact required resolution at trial.
Speak to a Capable New York Personal Injury Lawyer
If you were hurt in a rear-end collision, you may be entitled to compensation for your medical expenses, lost wages, and other damages. The capable Syracuse personal injury attorneys at DeFrancisco & Falgiatano Personal Injury Lawyers can advise you on the steps you can take to pursue justice. To set up a confidential consultation, you can contact us online or call us at 833-200-2000.