Saarinen v. Kerr, 84 N.Y.2d 494 (1994)
A municipality is entitled to a jury instruction on superseding causation when the evidence suggests an independent, unforeseeable act severed the link between the municipality’s negligence and the plaintiff’s injuries.
Summary
This case addresses the issue of superseding causation in the context of a high-speed car crash following a police pursuit. The New York Court of Appeals held that New York City was entitled to a jury instruction on superseding causation because the reckless conduct of the pursued driver might have been an unforeseeable act that relieved the city of liability. The court emphasized that the jury should have been allowed to determine whether the driver’s actions were a superseding cause, given the disputed facts and the potential for the jury to disbelieve parts of the plaintiff’s version of events. The court also found that there was no evidence to support the claim that inadequate lighting was a proximate cause of the accident.
Facts
At 3:30 a.m. on November 22, 1981, two police officers in a marked patrol car observed a car with its lights off cruising past a warehouse in the Bronx. After a disputed exchange between the officers and the occupants of the car, the plaintiff’s car sped away at high speed, running red lights and reaching speeds of up to 84 miles per hour in a 30-mph residential area. The police lost sight of the car within a minute, and approximately two minutes after fleeing, the car crashed into a tree as it approached the Cross Bronx Expressway. The plaintiff, a passenger in the fleeing vehicle, was seriously injured, and the driver was killed.
Procedural History
The plaintiff sued New York City, alleging negligence. The trial court entered judgment on a jury verdict in favor of the plaintiff. The Appellate Division affirmed. The New York Court of Appeals granted leave to appeal to the City.
Issue(s)
Whether the City was entitled to a jury instruction on superseding causation, given the evidence suggesting that the reckless conduct of the driver of plaintiff’s car was the sole, superseding cause of the accident.
Holding
Yes, because if the jury disbelieved the plaintiff’s version of events or gave greater credence to the defendant’s evidence, they could have concluded that the driver’s unforeseeable and dangerous flight was a superseding cause that relieved the City of liability.
Court’s Reasoning
The Court of Appeals reasoned that while causation is generally a question for the jury, the City was prejudiced by the trial court’s failure to provide a superseding causation instruction. The court stated that if the jury disbelieved parts of the plaintiff’s account or gave more weight to the City’s evidence, it could have found that the driver’s “unforeseeable, separable act of sudden, highly dangerous, independently driven flight” was the superseding cause. The court cited Kush v. City of Buffalo, noting that the jury should have been allowed to determine whether the driver’s actions broke the chain of causation between the initial police action and the ultimate injury. The court also found that the plaintiff’s claim that inadequate lighting contributed to the accident should have been dismissed because there was no evidence that the City had notice of the defect or that it was a proximate cause of the accident. The court emphasized the importance of proper jury instructions, stating that the trial court’s error “directly prejudiced defendant City and affected essential prongs of plaintiff’s and defendant’s theories of the case.”