Supreme Court Overturns Liability Ruling in Stolen Cab That Hit Pedestrian
“Causation, while a simple everyday word, is by no means a simple concept, in law or elsewhere, and its application to various questions of legal liability and damages has vexed our profession for at least the past one hundred years,” Justice Steven Ecker said in a special concurrence.
August 09, 2019 at 05:22 PM
4 minute read
The Connecticut Supreme Court reversed the Appellate Court Wednesday, finding Norwalk Yellow Cab can be held liable for a stolen taxi hitting a pedestrian.
At issue was whether the cab company should have been allowed to claim a defense from a third party’s “reckless superseding conduct.”
The case involves a cab driver who left his taxi unguarded on a high-crime street with the keys in the ignition. Two teenagers stole the taxi and took it on a joyride. When they crashed into the back of another car, they tried to escape by driving on the sidewalk. That’s when they hit and seriously injured Brenda Snell.
The taxi company claimed in its defense that while the cab being stolen may have been foreseeable, no one could have been expected to know it would be driven on a sidewalk, striking a pedestrian. The cab company won at trial and at the Connecticut Appellate Court. But Snell won Wednesday at the high court.
Justices Richard Palmer, Gregory D’Auria, Raheem Mullins, Maria Kahn and Steven Ecker agreed on the unsigned opinion. “The plaintiff is entitled to a new trial because the interrogatory responses on which the jury verdict was based are inconsistent as a matter of law,” they said.
Ecker wrote a separate concurrence.
“I agree with the majority’s well reasoned opinion and the result it reaches,” Ecker said. “First, and most significantly, I am troubled by the unnecessary and unfortunate prolixity of our superseding cause doctrine, or what remains of it. I understand that the majority is unable completely to escape the gravitational pull of existing doctrine, because the court’s ability to chart a new course, even with respect to the common law, is constrained by the arguments raised by the parties, who themselves are constrained by the perceived limitations imposed by our own precedent. In my view, the majority opinion nonetheless makes progress, incomplete but not insignificant, toward a more sensible and simplified doctrine.”
Ecker said his second reason for writing separately was that he disagreed with two points in the majority opinion, but they were minor and related to the “confusion generated by the superseding cause doctrine.”
“Causation, while a simple everyday word, is by no means a simple concept, in law or elsewhere, and its application to various questions of legal liability and damages has vexed our profession for at least the past one hundred years,” Ecker said. “That vexation is reflected in an unruly doctrine.”
Still, Ecker sounded hopeful.
“I believe that the majority has laid the groundwork to assist in the reconstruction of a simplified and more coherent doctrine,” he said.
And he blamed the confusing law, tort reform and apportionment, not Connecticut Superior Court Judge Kenneth Povodator, for any mistakes.
“The record demonstrates that the trial court did its best under difficult conditions to fashion a coherent jury instruction and useful jury interrogatories from the assorted pieces of the doctrinal jigsaw puzzle remaining in disarray on the table since tort reform was enacted,” Ecker said.
In the end, the Supreme Court reversed Povodator and ruled he gave the jury flawed instructions about the reckless superseding conduct defense.
Yellow Cab was represented by Laura Pascale Zaino and Kevin M. Roche of Halloran Sage in Hartford. They could not be reached immediately through calls and emails.
Snell was represented by Adam Blank of Wofsey, Rosen, Kweskin & Kuriansky in Stamford.
“We are thrilled to get an opportunity to get back in front of a jury and tell Brenda’s story,” Blank said Friday. “This decision reaffirms that which we all know, if you leave your keys in the ignition in a high-crime area, you take some of the responsibility for its theft and any injuries that result from the theft.”
Blank added, “If only the taxi driver would have turned his cab off and removed the keys, Brenda would not have needed countless surgeries and incurred millions of dollars in medical expenses.”
The case is Snell v. Norwalk Yellow Cab, No. SC 19929.
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