The Wyoming Supreme Court decided to send a wrongful death lawsuit against CRST International to trial last week.
The state-level supreme court justices voted 3-2 to overturn a February 2017 dismissal issued by the the District Court of Carbon County in favor of CRST.
The lawsuit was brought by the estate of David Crashley, 39, who died after colliding with a CRST truck parked in the emergency lane of Interstate-80 near Rawlins, Wyoming in February 2014.
It names CRST and two individual drivers, accusing both the employees and the company of negligence in parking and training, respectively.
What is known about the incident
The CRST drivers left Salt Lake City, Utah around midnight the night of the crash, stopping in the emergency lane at about 6:45 a.m. to change drivers. The truck’s hazard lights were turned on, according to the “facts” portion of an opinion issued by Wyoming Supreme Court.
The opinion goes on to state that the driver parked the truck in the emergency lane just over one mile past an off ramp leading to a truck stop and under one mile from the next highway exit. It also states that multiple signs in the area prohibited non-emergency parking.
Crashley’s Mazda CX-9 left the roadway and crashed into the truck at speeds estimated between 60 and 80 mph, killing him on impact. Crashley did not attempt to brake before hitting the truck, according to court documents.
The district court’s decision
Attorneys representing CRST in district court argued that the company was not responsible for Crashley’s death because the parked truck was not impeding his ability to safely drive on the highway. They argued that the man crashed because he lost control of his vehicle and entered the emergency lane, where he was not legally allowed to drive.
The district court issued a summary judgement in favor of CRST, and the Crashley’s estate appealed that judgement.
“On November 17, 2016, Appellees filed a motion for summary judgment. Appellees asserted they were entitled to summary judgment as a matter of law because Mr. Chavez’s act of parking in the emergency lane, even if illegal, was not the proximate cause of the decedent’s accident,” the opinion reads. “On January 11, 2017, [the estate] filed its opposition to Appellees’ summary judgment motion. After a hearing, the district court granted the motion for summary judgment. This timely appeal followed.”
A summary judgement is a judgement issued by the court in favor of one party without a full trial.
All about proximate cause
This case centers around whether or not CRST acted as a proximate cause for Crashley’s accident and subsequent death.
There are several legal theories that attempt to define proximate cause, but the most common is foreseeability. This means that proximate cause is met if an injury resulting from an action could have been predicted.
To determine proximate cause in this case, one would have to determine whether or not a reasonable person could predict that the CRST drivers parking in the emergency lane could cause Crashley to have a fatal accident.
“The central goal of the proximate cause requirement is to limit the defendant’s liability to the kinds of harms he risked by his negligent conduct,” the Wyoming Supreme Court opinion reads. “Judicial decisions about proximate cause rules thus attempt to discern whether, in the particular case before the court, the harm that resulted from the defendant’s negligence is so clearly outside the risks he created that it would be unjust or at least impractical to impose liability.”
The three justices who voted to overturn the district court’s decision stated that illegally parking the truck in the emergency lane caused a foreseeable risk to passing motorists, citing Cabral v. Ralph's Grocery Co., a similar case from the California Supreme Court.
“We agree with the reasoning of the California Supreme Court. The dangers to highway users presented by a parked tractor-trailer along I-80 are no less foreseeable in Wyoming than they are in California,” the opinion states. “In Cabral, the parked vehicle arguably posed less of a danger. It was parked 16 feet off the traveled portion of the highway. In this case, portions of the tractor-trailer were within ten inches of the eastbound lanes of I-80.”
When the state supreme court decided to send the case to trial, it stated that proximate cause is generally decided by a jury.
The two dissenting justices argued that the majority failed to recognize the differences between Wyoming’s modified comparative negligence model and California’s pure comparative negligence model.
The modified model states that the plaintiff cannot be more than 50 percent responsible for the injury in question for the defendant to be held liable. The pure model allows each party to be held liable for their percentage of the fault, regardless of what those percentages end up being.
CRST International General Counsel Lisa Stephenson released a statement agreeing with the dissenting justices and the earlier district court decision.
“CRST agrees with the trial court judge and the members of the Wyoming Supreme Court who decided that CRST was not, as a matter of law, a proximate cause of this tragic accident,” Stephenson said. “While a narrow majority of the appellate court has determined that a jury must decide the question of proximate cause, CRST is confident that a jury will also reach the conclusion that CRST was not a proximate cause of this accident.
A trial date has not yet been announced.