Causation is a necessary element of any Maryland personal injury lawsuit. Briefly, the causation requirement is met if the plaintiff can establish that the defendant’s actions brought about the plaintiff’s harm. While that may sound like a fairly straightforward determination, the reality is that much litigation is focused around the causation element. A recent case details how one state’s supreme court conducted a causation analysis. The case is important to Maryland car accident victims because, while the specific law applied in Maryland courts is slightly different, similar principles do apply.
The plaintiffs were the parents of a student who was injured while running with his school’s cross-country team. The injury occurred when the plaintiffs’ son was instructed to cross the street against a red light by the track coach, who was running with the team. As the boy entered the intersection, he was struck by a passing vehicle, resulting in serious injuries.
The boy’s parents filed a personal injury lawsuit against the coach, arguing that he was responsible for their son’s injury. The parents also named the driver of the car that struck their son, although that case was not discussed in the opinion.
The coach argued that as a government employee, he was entitled to immunity from the lawsuit under the government tort liability act (GTLA). Briefly, the GTLA provides immunity to government actors whose negligence causes someone to be injured. However, the GTLA does not provide immunity if the government employee’s actions were grossly negligent and are determined to be the proximate cause of the injury. The coach argued that he was not grossly negligent and that it was the other driver’s conduct – rather than his own – that was the proximate cause of the plaintiffs’ son’s injury.
The trial court believed that the jury should decide whether the coach was entitled to immunity. Not satisfied with this result, the parents appealed to the intermediate appellate court. That court reversed in favor of the coach, agreeing that it was the other driver’s negligence in conjunction with the plaintiffs’ son’s negligence that were the proximate cause of his injuries. The plaintiffs appealed again, this time to the state’s supreme court.
The state supreme court took issue with the intermediate court’s analysis and remanded the case back to the intermediate appellate court for further analysis to be conducted. The court explained that the proximate-cause determination does not require or permit a judge to weigh various parties’ fault. Instead, the court should consider whether the defendant’s actions were the “most immediate, efficient, and direct” cause of the plaintiff’s injuries. If so, the defendant’s actions are said to be a proximate cause. Since the intermediate court applied the wrong legal analysis, the high court sent the case back so that the court could decide the case under the proper framework.
Have You Been Injured in a Maryland Car Accident?
If you or a loved one has recently been injured in a Maryland car accident, you may be entitled to monetary compensation. As you can see from the discussion above, even a seemingly simple case can turn into an intellectual quagmire, resulting in months of dragged-out litigation. The dedicated Maryland personal injury lawyers at the law firm of Lebowitz & Mzhen Personal Injury Lawyers have extensive experience handling all kinds of Maryland personal injury cases, including complex auto accident cases. To learn more, and to speak with an attorney about your case, call 410-654-3600 to schedule a free consultation with an attorney today.
More Blog Posts:
Recent Case Finds Hotel Was Not Liable for Poolside Accident Caused by Drunk Driver, Maryland Car Accident Attorney Blog, published August 2, 2017.
Court Allows Evidence of “Other Similar Incidents” in Recent Product Liability Car Accident Case, Maryland Car Accident Attorney Blog, published July 11, 2017.