Request for New Trial Denied Where Defendant Driver Found Negligent But Jury Found Causation Element Not Met in Fatal MVA Case

In the case of Steudler v. Keating, No. 8795 - CV - 2013 (C.P. Monroe Co. March 20, 2018 Williamson, J.), Judge David J. Williamson ruled that Plaintiffs were not entitled to a new trial based upon the jury’s failure to find causation even though it found the Defendant driver negligent in an auto accident case. 

The court ruled in this fashion after finding that it was possible for the jury to determine that the Defendant was negligent but that his negligence was not the factual cause of a fatal accident.  

According to the Opinion, the Plaintiffs, Erika Steudler and Victor Resto, were walking along a road in Monroe County when Resto was struck by a motor vehicle driven by the Defendant.  

The court noted that the accident occurred at night on a country back road with no street lighting.   Neither Plaintiff was carrying a flashlight at the time of the accident.  

Plaintiff Steudler did not see the accident but felt Resto brush against her the darkness when he was thrown in the air.  

Steudler filed a lawsuit against the Defendant seeking emotional damages due to witnessing the accident while Resto’s estate filed a wrongful death claim.

As noted, the matters proceeded to trial where the jury found the Defendant negligent but also found that his actions were not the factual cause of the Plaintiffs’ injuries.  

In the post-trial motions, the Plaintiffs asserted that the verdict was against the weight of the evidence and shocking to one’s sense of justice.   The Plaintiffs argued that, because the jury found that the Defendant was negligent, the jury should have found that he was also the factual cause of their injuries since it was undisputed that Resto died from the accident.  

The court ruled that a verdict is not against the weight of the evidence simply because the evidence at trial was conflicting or that a reasonable fact-finder could have decided the case in favor of either party.  

The trial court distinguished this case from the line of cases which suggest that when a Defendant is found negligent and both parties admit that there was some injury, then the Defendant must be found to have caused at least some portion of the injuries alleged.   Here, the court noted that the most distinguishable factor between that line of cases and this case was the issue of the Plaintiffs’ contributory negligence.   The court noted that, in the line of cases cited the Plaintiffs, the Defendants had admitted negligence and there was no difference in opinion that the Defendants’ negligence had caused those accidents, which cause some personal injury.  

In the Steudler matter, the Defendant never admitted negligence and there were claims of contributory negligence pursued.   The defense argued that the sole cause of the accident was the Plaintiffs’ own acts or omissions.   It was the Defendant’s defense that he operated his vehicle within the posted speed limit, stayed within his lane of travel, and never saw the Plaintiffs prior to the impact.  

The court also noted that the parties presented experts with different opinions on the theory of the cause of the accident in this matter.

In the end, the court found that the jury’s verdict in this matter could have been based upon the jury’s belief that Resto was in the roadway, together with Steudler, and that, if he was not, he may not have been struck and killed. 

As such, the court denied the Plaintiff’s request for a new trial under the case presented.

Anyone wishing to review a copy of this decision may click this LINK. 

Source:  “Digest of Recent Opinions” Pennsylvania Law Weekly (April 10, 2018).