6 N.Y.3d 487 (2006)
A plaintiff’s reckless conduct, even when contributing substantially to their injuries, does not automatically absolve a defendant of liability if the defendant also acted negligently and the plaintiff’s conduct was not a superseding cause.
Summary
Juan Soto, after consuming alcohol, walked along a subway catwalk with friends. Attempting to catch a train, he was struck and severely injured. At trial, Soto testified about his estimated running speed, which an expert used to argue the train could have stopped in time. The jury found the NYCTA negligent, assigning 25% fault to them and 75% to Soto. The Court of Appeals affirmed, holding that while Soto’s conduct was reckless, it wasn’t a superseding cause that relieved the NYCTA of its duty of care, and that Soto’s speed estimate was properly admitted as evidence.
Facts
Plaintiff, 18 years old, spent an evening drinking alcohol with friends. In the early morning, the group walked along a subway catwalk after determining the train was not running. As a train approached, they ran to catch it, and plaintiff was struck, resulting in the amputation of both legs below the knee. Plaintiff testified he was running about 7-8 miles per hour. The train operator gave inconsistent accounts of the incident.
Procedural History
Plaintiff sued the NYCTA. The jury found the NYCTA negligent and apportioned fault. The trial court denied the NYCTA’s motion to set aside the verdict. The Appellate Division affirmed the jury verdict, with two justices dissenting. The NYCTA appealed to the Court of Appeals.
Issue(s)
1. Whether the plaintiff’s reckless conduct was the sole proximate cause of his injuries, thus relieving the defendant of liability.
2. Whether the plaintiff’s estimate of his running speed was admissible as evidence.
Holding
1. No, because the jury could reasonably find that the train operator was also negligent and the plaintiff’s conduct was not a superseding cause.
2. Yes, because the plaintiff established a sufficient foundation demonstrating the basis of his knowledge about running speed.
Court’s Reasoning
The court reasoned that the jury’s verdict should stand if there was a valid line of reasoning and permissible inferences that could lead rational people to the conclusion reached by the jury. The court found that the jury appropriately considered the plaintiff’s actions and applied the doctrine of comparative negligence. The court distinguished this case from situations involving dangerous, illegal conduct, emphasizing that while the plaintiff contributed to his injury, he did not engage in conduct that automatically barred recovery. The court cited Coleman v. New York City Tr. Auth., stating a train operator may be found negligent if they see a person on the tracks from a distance that would allow them to stop the train. The court found no error in admitting the plaintiff’s testimony regarding his running speed because he had a basis for estimating his speed from running on a treadmill. The court stated: “The reliability of plaintiff’s testimony and the weight it should have been accorded were issues for the finders of fact.” The dissenting judge argued that the plaintiff’s recklessness was so egregious that it superseded the defendant’s conduct and became the sole proximate cause of his injuries, citing cases where plaintiffs who put themselves in the path of trains were denied recovery. The dissent emphasized the extraordinary degree of the plaintiff’s fault, arguing that people whose failure to take care of themselves is extreme should not shift consequences to others.