Court Rules That Vehicle Caused To Suddenly Stop in Traffic Could Potentially Be Liable to Operator of Vehicle that Rear Ended the Stopped Vehicle

In the case of Cleveland Brothers Equipment Co., Inc. v. Vorobey, No. 4:19-CV-01708 (M.D.Pa. 2020 Brann, J.), the court addressed whether the sudden stoppage of a vehicle ahead on the roadway, which is followed by a rear-end collision, can result in liability on the stopping vehicle.

In reviewing the Motion for Summary Judgment in this case, the court reviewed the facts of a multi-vehicle accident. According to the Opinion, there was an earlier accident on the opposite side of the highway, as a result of which, some debris allegedly spilled over into the other side of the highway, causing traffic to stop or slow on that side of the highway.  A tractor trailer driver came to a stop in the stopped traffic and, shortly thereafter, several vehicles were allegedly rear-ended by another commercial vehicle.

The Defendant tractor trailer driver who had stopped ahead was the party who filed a Motion for Summary Judgment in this matter asserting that the operator of rear-ending vehicle who asserted liability claims against the stopped tractor trailer driver could not establish liability on the stopped vehicle.

Judge Brann indicated that the issues of liability presented was one to be decided by a jury. The court also noted that “sudden stoppage of a vehicle on the roadway…may create factual issues surrounding the proximate cause of an accident involving rear-end collision behind the stopped vehicle.” 

The court in this regard cited to the cases of Doland v. Berrios, 2014 WL 3809962 at *3 (M.D. Pa. 2014) and Gensemer v. Williams, 419 F.2d 1361, 1362 (3d. Cir. 1970) in support of its decision. 

As such, the court denied the Motion for Summary Judgment and allowed the issues to proceed to the jury.


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

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