David Blood v. Vh-1 Music First
668 F.3d 543
7th Cir.2012Background
- Hernandez caused a three-car crash on I-57 in Southern Illinois, closing northbound lanes for hours.
- The resultant traffic jam stretched four to five miles; four hours later, Cukovic rear-ended Blood, killing Paul Blood and injuring David Blood.
- David Blood and Mary Blood sued Cukovic and T.E.A.M. Logistics; they removed to district court and third-party complaints were filed against the Hernandez defendants.
- The district court granted summary judgment for the Hernandez defendants, finding Blood could not prove proximate causation.
- Illinois law governs the negligence claim, requiring duty, breach, and proximate causation, with proximate cause including both cause in fact and legal cause.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hernandez proximate caused Blood’s injuries as a matter of law | Blood argues Hernandez’s first collision causally led to the second accident | Hernandez contends the four-hour gap and the subsequent intervening act break proximate causation | No proximate causation as a matter of law; district court affirmed summary judgment |
Key Cases Cited
- Anderson v. Jones, 213 N.E.2d 627 (Ill. App. Ct. 1966) (four-factor analysis for successive accidents; not proximate if break in causal chain)
- Cox v. Stutts, 474 N.E.2d 1382 (Ill. App. Ct. 1985) (proximate causation in multi-vehicle crashes; factual disputes often for jury)
- Cherry v. McDonald, 531 N.E.2d 78 (Ill. App. Ct. 1988) (multiple minutes between collisions; jury could reasonably decide proximate cause)
- Knoblauch v. DEF Express Corp., 86 F.3d 684 (7th Cir. 1996) (fact disputes can preclude summary judgment where reasonable jurors could differ)
- Merlo v. Pub. Serv. Co. of N. Ill., 45 N.E.2d 665 (Ill. 1942) (proximate cause may be decided as a matter of law when facts are undisputed)