Massachusetts Court of Appeals Rules in Favor of Defendant Who Experienced Seizure Before Causing Car Crash

Cape Cod car accident cases require the plaintiff to prove, by a preponderance of the evidence, that the defendant breached the applicable duty of care and that this breach of care was the proximate cause of the damages for which the plaintiff seeks compensation. Generally speaking, a defendant who crashes her car into an innocent motorist will probably be found to have violated the duty to keep a proper lookout.

However, there are exceptions to this rule. The defendant’s liability hinges on whether he or she failed to act in a reasonably prudent manner, hence causing the accident. There are several factors that can come into play in determining whether the defendant’s actions were reasonable.

Although the issue does not come up very often, it is possible that the defendant may be able to avoid liability by proving that he or she was incapable of acting in a reasonably prudent manner. An example would be a motorist who experiences a sudden medical emergency that causes him or her to lose control of his or her vehicle. While such an event will not always relieve the defendant of responsibility for an accident, there is a good chance that it could. After all, the purpose of negligence law is to encourage individuals to act reasonably. When a medical emergency arises, this may not be possible.

Facts of the Case

In an (unreported) case recently under consideration by the Commonwealth of Massachusetts Appeals Court, the plaintiffs were a mother and father, suing individually and as the parents/next friends of a minor child who was injured in what was described by the court as a “high-speed crash” in 2017. The mother was also injured in the accident. The plaintiffs sought to recover fair compensation for the injuries suffered in the crash, asserting that the wreck was the fault of the defendant motorist. In response, the defendant moved for dismissal of the plaintiffs’ complaint on summary judgment. The trial court granted the defendant’s motion, and the plaintiffs appealed.

Decision of the Court

The appeals court affirmed the lower court’s judgment in favor of the defendant. In so holding, the court acknowledged that both parties’ medical experts had agreed that the defendant had suffered a sudden medical emergency while driving. The plaintiffs maintained that the defendant should, nevertheless, be held liable for the plaintiffs’ injuries because, despite the seizure that caused her to lose control of her vehicle, she had momentarily regained the ability to control her vehicle. The plaintiffs further asserted that the defendant’s seizure had been foreseeable.

In rejecting the plaintiffs’ contentions and siding with the defendant on appeal, the court pointed out that the defendant had been in a postictal state following the accident and that her seizure had been the result of an undiagnosed brain tumor. The primary witness to the accident, the defendant’s passenger at the time of the collision, stated that the defendant had lost consciousness shortly before the accident and that she (the witness) had been unable to rouse the defendant prior to the crash. The court further noted that the defendant, although in her 70s, had enjoyed excellent health prior to the accident; although she had experienced a headache a few days before the crash, there was nothing to suggest that, had the plaintiff sought medical treatment for the headache, the appropriated standard of care would have included the type of medical imaging that would have disclosed the presence of the brain tumor.

Get Advice About Your Car Accident Case

If you have been involved in an automobile accident and have questions about your legal rights, please contact the Law Offices of John C. Manoog III at 888-262-6664. We will be glad to explain the process of seeking fair compensation for injuries suffered in a Hyannis or Plymouth car crash.