The U.S. Court of Appeals for the Fourth Circuit ruled within recent months to deny a judgment for the defendant in a complex truck accident case. The Fourth Circuit Court of Appeals is the federal appellate court to which all district court cases in Maryland are appealed. Therefore, this decision is instructive for Maryland trucking accident cases.
In PITT OHIO EXPRESS, LLC v. PAT SALMON & SONS, INC., Ct. App., 4th Cir. (2013), three commercial trucks and one passenger vehicle were involved in a collision.
Truck A, owned by “C. Bean” slowed down due to foggy conditions. Truck B, owned by “Pat Salmon” collided into the back of Truck A, which caused only minor damage to both trucks, but disabled truck A, and caused it to at least partially obstruct both lanes of traffic. Within seconds, a passenger vehicle approached, and attempted to brake, at that point Truck C, owned by “Pitt Ohio” collided into the back of the passenger vehicle, propelling the car into the back of Truck B. Both occupants of the passenger vehicle and a passenger who had exited Truck B were killed as a result of the collision.
Following the collision, the driver of Truck B was charged with reckless driving, and pleaded guilty to a lesser offense. The owner of Truck C settled with the estates of the three individuals who were killed in the accident. The owner of Truck C then filed this action in federal court seeking contribution from the owners of the other two trucks for their joint liability in the collisions and resulting settlements. The owner of Truck B lost at trial, and Truck C was awarded a judgment of $687,500. Truck B appealed.
The Court of Appeals reviewed the standards for what Truck B was seeking, which was judgment as a matter of law, or a new trial. The decision whether to grant a new trial, absent an abuse of discretion, is within the sound discretion of the trial court. Therefore, in this case, a new trial was not within the province of the appeals court. Regarding a judgment, the court looks to whether there was evidence that the jury could reasonably relied upon in reaching its decision.
Given those two standards, the court held, the jury verdict should be sustained. Based on the evidence presented, the jury could have found that the driver of Truck B was driving negligently. It was up to the jury to determine what due care required given the circumstances, and whether or not it was exercised. Additionally, it was the proper province of the jury to evaluate the driver’s testimony and other evidence regarding his culpability in causing the accident.
Therefore, due to a lack of abuse of discretion, and reasonable evidence upon which the jury could have reached the conclusion that it did, the judgment was affirmed.
This case is atypical in that it involves the premise of joint and several liability. Under that legal doctrine, several defendants are deemed to all be equally at fault for having caused an injury, yet a judgment against one of them does not resolve the liability of the others. It is under this premise that Truck C sought contribution against the others.
Absent a waiver from the estates of the individuals killed, those individuals could have sought compensation against Truck B as well as Truck C, if they wished, since the two were potentially both equally liable. In other words, the outcome of this decision, as between the two truck companies has no impact on the ability of the victims to sue the two companies separately.
If you or a loved one has been injured or killed in a trucking accident that occurred in the Maryland or Washington D.C. areas, contact the experienced trucking accident attorneys at Lebowitz & Mzhen, LLC today. Our law firm has extensive experience in handling trucking accident cases, and we will fight to ensure that you recover the damages that you deserve. Contact us today in order to schedule your free initial consultation, and learn how we can help you. You can reach us by calling 1-800-654-1949 or through this website.
More Blog Posts:
U.S. Court of Appeals Affirms Wilhem Test, Expert Testimony Unnecessary to Prove Back Injuries In Truck Accident, Maryland Trucking Accident Lawyer Blog, published November 20, 2013
Overturned 18 Wheeler 3 Vehicle Accident on Route 50 in Anne Arundel County, Maryland Trucking Accident Lawyer Blog, published November 14, 2013