Rawls v. Progressive Northern Insurance Co., 310 Conn. 768

Summary

The Connecticut Supreme Court reversed the Appellate Court and held that the evidence was sufficient for a jury to reasonably find that the defendant was negligent and that the negligence proximately caused a rear-end collision. The court explained that negligence and causation may be established through circumstantial evidence and that a collision alone is insufficient, but the totality of the circumstances may support a finding that negligence was more likely than not. The case concerned claims for negligence and underinsured motorist benefits.

Holdings

1. A plaintiff need not prove that negligence and causation were the only possible explanations for a collision; the plaintiff must present some direct or circumstantial evidence from which the jury reasonably could find that negligence and causation were more likely than not. The totality of the evidence here was sufficient to support the jury's findings that Bailey was negligent and that his negligence proximately caused the collision.
2. The Appellate Court's reliance on O'Brien, Schweiger, Palmieri, Chasse, Winn, Terminal Taxi, and Hicks was misplaced because those cases involved materially different evidentiary circumstances; they did not establish a bright-line rule requiring eyewitness testimony or treating every rear-end collision as insufficient evidence of negligence and causation.

Questions Presented

1. Whether the evidence, viewed in the light most favorable to the plaintiff, was sufficient for a jury reasonably to find that Bailey was negligent and that his negligence proximately caused the rear-end collision.
2. Whether the Appellate Court improperly reversed the trial court's denial of Progressive's motions for a directed verdict and to set aside the jury verdict.

Disposition

reversed_and_remanded