Summary
This Appellate Division, Third Department opinion addresses a negligence action brought by motorcycle passengers against the State of New York following a collision at an intersection with known visual obstructions. The trial court found the State 75% liable for failing to adequately remedy the dangerous sight-distance conditions, while assigning 25% liability to a third-party driver who failed to yield. On appeal, the State argued that the third party's negligence severed the chain of proximate cause. The court affirmed the judgment, holding that the State's breach increased the likelihood of the accident and that the intervening negligence was a foreseeable consequence of the maintained dangerous condition.
Topics
Practice areas
Questions Presented
- Whether the State's negligence in maintaining the intersection was a proximate cause of the accident
- Whether Ohlsten's negligence was a superseding intervening cause that broke the causal chain
Holdings
- The State's failure to study and adequately remedy the known dangerous condition was a proximate cause of the accident.
- Ohlsten's negligence was a foreseeable consequence of the State's negligence and did not break the causal nexus; therefore the State remains liable.
Key quotations
“defendant's breach plainly "increased the likelihood of an accident" in the manner that ultimately occurred”
“Only where the intervening act is extraordinary under the circumstances, not foreseeable in the normal course of events, or independent of or far removed from the defendant's conduct, may it possibly break the causal nexus”
Factual background
In August 2017 claimants on a trike motorcycle were struck at an intersection in the Town of Bellmont by an SUV driven by Lynn Ohlsten. The intersection had visual obstructions and the State had known for years of sight‑distance problems but had taken only minimal remedial steps. Ohlsten failed to yield the right‑of‑way and collided with the claimants.
Procedural history
The Court of Claims found the State 75% liable and the driver Ohlsten 25% liable for the 2017 intersection accident and entered a final judgment in favor of the claimants.