The Necessity of Proving Causation in Tennessee Auto Accident Claims – Denton v. Taylor

When a plaintiff brings a claim in an auto accident or personal injury case, he or she generally bears the responsibility of proving by a preponderance of the evidence that the actions of the defendant fell below a standard of care and contributed to his or her injuries.  A failure to prove any one of these elements can lead to a claim being denied. For instance, if the plaintiff cannot show that injuries were suffered, there may not be damages for the jury to award. And if the defendant was taking all necessary precautions and acting with the utmost responsibility, a jury may find that although injuries occurred, the defendant did not act negligently in causing them.  When approaching a personal injury lawsuit, it is important that plaintiffs not forget their burden to prove the elements of their claim. Assumptions that elements can be presumed, or inferred from the circumstances, can lead to disappointment and financial losses.

In Denton v. Taylor, the Tennessee Court of Appeals looked at whether a plaintiff who was injured in an automobile accident case alleged facts sufficient to establish causation.  Howard Taylor and Christopher Denton were involved in an accident in which Mr. Taylor was killed and Mr. Denton incurred serious injuries.  There were no witnesses to the accident. When it was discovered, Mr. Denton was immediately transported to the emergency room, but he could not recall any details surrounding the accident.  A sheriff’s deputy who arrived at the scene and examined the accident prepared a report but could not identify the point of impact for the accident or additional information concerning how the accident occurred.  Later, when Mr. Taylor’s body was examined, it was determined that he had significant amounts of opiates in his system.  Mr. Denton ultimately filed a lawsuit against Mr. Taylor’s widow and his estate, alleging that Mr. Taylor’s negligence led to his injuries.

After discovery commenced, and interviews were taken of Mr. Denton and the responding officers, Ms. Taylor moved for summary judgment against the plaintiff, alleging that there was insufficient evidence to establish that Mr. Taylor caused Mr. Denton’s injuries.  Ms. Taylor relied on the fact that no individual had any recollection of how the accident had occurred, and officers had been unable to piece the accident together after the fact. Accordingly, Ms. Taylor argued that Mr. Denton had not met his burden of proof. Mr. Denton responded by pointing to evidence that Mr. Taylor had significant opiates in his system, which he argued led to the conclusion that Mr. Taylor was likely driving under the influence, was negligent, and caused the accident. While the trial court agreed that it would have been negligent for Mr. Taylor to drive under the influence of drugs, it held that Mr. Denton had presented no evidence to show that Mr. Taylor’s driving actually caused the accident or Mr. Denton’s injuries.  Mr. Denton appealed.

On appeal, the court confirmed the lower court’s ruling on summary judgment. Acknowledging the significant deference given to trial courts when evaluating summary judgment motions, the appeals court confirmed the holding that Mr. Denton had not provided sufficient evidence of causation, given that no one had a memory of the accident, there were no witnesses, and no one had been able to reconstruct the accident. In light of these factors, the court held that Mr. Denton simply had not offered evidence to prove that Mr. Taylor caused his injuries.

In the emotion and excitement of an accident, it can be easy to presume that your facts are obvious and so egregious as to clearly prove your case. But courts must carefully consider each of the elements of a claim, putting aside emotion or intrigue. When a plaintiff fails to establish basic facts, such as how an accident occurred, a court may be forced into a position of denying a claim.

If you have recently been a victim of an automobile accident in which there were few witnesses, knowledgeable Tennessee car accident attorney Eric Beasley can help you identify and collect the facts and evidence necessary to prove your claim. 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:

Government Liability in Tennessee for Automobile Accidents Involving Police Officers, Tennessee Personal Injury Blog, April 13, 2016

Tennessee Accident Tips, Tennessee Personal Injury Blog, March 16, 2016

Tennessee Courts Find Presumption of Comparative Fault for Drivers Running a Light, Tennessee Personal Injury Blog, January 6, 2016


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