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Proximate Cause Necessary to Establish Liability in Trucking Accidents, Sunbelt Environmental, Inc. v. Gulf Coast Truck & Equipment Company, Inc., Case No. 1D10-6079 (Fla 1st DCA 2012)

The issue of causation is a critical part of any negligence case, including truck accident suits. As illustrated in the case below, courts must establish proximate cause of an injury before it can decide whether a truck driver or trucking company is liable for injuries from a truck accident. Proximate cause is a legal concept that refers to an action that causes injury as a direct, natural, and uninterrupted consequence. In other words, without such proximate cause, the injury would not have occurred.

In Sunbelt Environmental, Inc. v. Gulf Coast Truck & Equipment Company, Inc., a bicycle rider was hit by a garbage truck that was passing the rider on the street. The part of the garbage truck that crashed into the bicyclist was a tarp that made the garbage truck too wide in violation of Florida law. The bicycle rider suffered serious injuries and required an amputation as a result of the accident. The rider filed suit against the garbage collection company, and the parties entered a settlement agreement. The garbage collection company then sued the truck manufacturer that installed the tarp on the truck in question that made it too wide. The company claimed that the manufacturer was negligent and was strictly liable for its negligent design of the tarp that made the garbage truck overly broad. However, the manufacturer filed a motion for summary judgment, contending that they were not liable because the driver of the truck, who was an employee of the garbage collection company, was negligent in failing to pass the bike rider at a safe distance of at least three feet in violation of Florida statute. Additionally, they claimed that the driver negligently failed to decrease speed to avoid crashing into the rider.

The trial court ruled for the manufacturer, stating that even though the truck exceeded legal width limits, the garbage company was required to ensure that the truck complied with the applicable law. The court also found that the garbage company replaced the tarping unit in question using its employees; therefore, it assumed the risk that came with its labor. Therefore, the court determined that the manufacturer was not liable for the width of the garbage truck.  The garbage company appealed.

The First District Court of Appeals of Florida heard the case and reversed the trial court’s decision on appeal. The Court decided that the trial court should have first determined the proximate cause of the bike rider’s injury. The appeals court determined that the trial court must first consider whether the length of the garbage truck’s arm was a proximate cause of the biker’s injury. The trial court should have determined whether other factors, such as the road conditions, the biker’s clothing, and the truck driver’s manner of driving, combined to cause the injury. According to the Court, the trial court could not determine the issue of liability without first establishing proximate cause. The Court decided that the trial court’s decision that the garbage collection company was solely responsible for keeping the garbage truck in proper condition did not establish the garbage collection company’s liability without determining that the truck was too wide and whether that extra width proximately caused the biker’s injuries.

If you or a loved one has been injured in a truck accident because of a driver’s or trucking company’s negligence, the Miami personal injury lawyers at Greenberg, Stone & Urbano offer the assistance you need to obtain the results you desire.  With over 130 collective years of experience representing personal injury clients across South Florida, our firm provides legal representation of unmatched excellence.  Contact our firm as soon as possible to start on the road to protecting your legal rights.  Our firm received an AV rating from Martindale-Hubbell and was ranked as a top firm in South Florida by the Miami Herald.   Put our exceptional personal injury attorneys to work on your case.  Call us at (888) 499-9700 or (305) 595-2400 or you can visit our website to schedule your initial consultation.

 

 

 

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