Can there be a presumption of comparative negligence when a driver fails to abide by traffic lights and signals? A Tennessee court recently addressed this issue while considering claims for negligence resulting from an automobile accident.
In Vaal Hall v. Charles L. Owens Jr., et al., the plaintiff, Vaal Hall, sued the defendant, Charles Owens, Jr., for injuries resulting from an accident that occurred on November 3, 2009. That morning, Mr. Hall was driving his car when he approached a local intersection in the southbound direction. Although the left-turn signal was red at the time, Mr. Hall entered the left-turn lane and prepared to turn. At the same time, Mr. Owens was driving a tractor trailer headed northbound through this intersection. His light was green as he approached, and he continued through the intersection at the same time that Mr. Hall proceeded to turn left. Mr. Owens attempted to avoid a collision with Mr. Hall, but his truck hit the passenger side of Mr. Hall’s vehicle, and Mr. Hall suffered serious injuries.
Despite these facts, in November 2010, Mr. Hall filed a claim of negligence against Mr. Owens, requesting $10 million in damages resulting from his injuries. Mr. Hall alleged that, based on evidence collected from the scene, Mr. Owens appeared to have been driving 5-10 miles per hour above the speed limit when he entered the intersection, and this negligent speeding contributed to the accident and Mr. Hall’s injuries.
Tennessee law uses a modified comparative fault approach to deciding negligence in auto accident and personal injury claims. This means that in order for a plaintiff to recover damages from a defendant, the plaintiff’s fault must be less than the defendant’s, and damages will be reduced according to the percentage of fault attributed to the plaintiff. Thus, for instance, a plaintiff who is 30 percent at fault can recover from a defendant who is 70 percent at fault, but the plaintiff’s damages will be reduced by 30 percent.
In this case, Mr. Owens filed a motion for summary judgment on Mr. Hall’s claims, arguing that based on the fact that Mr. Hall had turned left while the traffic light was red, no reasonable jury could find him less than 50 percent at fault for the accident, and thus he could not succeed under the modified comparative fault system. The trial court agreed and dismissed Mr. Hall’s claims. Mr. Hall appealed.
On appeal, the Tennessee Court of Appeals upheld the lower court’s decision, finding that it was undisputed that Mr. Hall had made an illegal left turn “across the path of oncoming traffic” and that this action had set the collision in motion. Accordingly, the court determined that no reasonable juror could possibly find that Mr. Hall was less than 50 percent at fault for an accident in which Mr. Hall ran the red light himself. In such circumstances, the court concluded that a juror could only determine that Mr. Hall was himself primarily responsible for the accident that occurred, and thus he was not entitled to damages from Mr. Owen.
While the court’s decision in this case does not unequivocally state that running a red light will render a driver primarily negligent for any accident that occurs, since other factors can arise that affect a negligence calculation, the language of the court’s decision suggests a strong presumption of partial fault when a driver engages in such illegal behaviors.
If you have recently been the victim of a car crash, knowledgeable auto accident attorney Eric Beasley can help you in evaluating your situation under Tennessee’s modified comparative fault system to determine whether you may be entitled to damages. For more information or to discuss the circumstances of your case, contact the Law Office of Eric Beasley today at 615-859-2223.
Related Blog Posts:
Tennessee Lawmakers Encourage Automobile Safety Through Increased Seatbelt Fines, Tennessee Personal Injury Blog, December 28, 2015
Tennessee Personal Injury Claims Increase Despite Reduction in Auto Accidents, Tennessee Personal Injury Blog, October 15, 2015
Tennessee Auto Accident Guide – What to Do and When, Tennessee Personal Injury Blog, October 2, 2015