MOTOR VEHICLE TORTS: Connecticut Supreme Court overturns Appellate Court finding of no liability in rear-end motor vehicle accident case

In 2011, the Connecticut Appellate Courts held that in this rear-end motor vehicle accident case, where the only evidence is that the plaintiff heard a loud noise prior to his vehicle being struck from behind there was insufficient evidence to establish negligence on the part of the defendant driver.  On further appeal, the Connecticut Supreme Court reverses, holding that there was sufficient circumstantial evidence from which the jury could have concluded, reasonably, that negligence existed.  “A plaintiff is not required to disprove all other possible explanations for an accident, but, rather, must demonstrate that it is more likely than not that the defendant’s negligence was the cause of the accident.”

The Court notes that although it was “possible that [the plaintiff’s vehicle] could have experienced a mechanical failure, or that [the plaintiff] could have suffered from an acute medical condition or encountered a road hazard” those explanations were “far less likely” under the facts of the case than the explanation offered by the plaintiff, that the defendant was not paying attention at the time of the collision. The jury could have considered the fact that the plaintiff was stopped at a red traffic light for about 15 seconds, and that such lights are normally highly visible to drivers.  The jury could also have considered that because the weather was clear and the roads were flat and straight, the light and two stopped cars at the light were probably visible from a great distance.  Additionally, the jury could have inferred that the light was red for at least 15 seconds or more and that the defendant would have had ample time to react and avoid the collision if he was acting with reasonable care.

Walls v. Progressive Northern Ins. Co., SC 18855 (January 7, 2014)