Eunique Williams v. Chicara Alston, No
154 A.3d 456
| R.I. | 2017Background
- On August 31, 2012, plaintiff Eunique Williams was working as a crossing guard at Park and Wellington Avenues in Cranston and was struck and seriously injured after being hit by a pickup truck spun into her following a collision.
- Co-defendant Chicara Alston ran a red light on Wellington, crossed into oncoming traffic, and collided with Rick M. Ford’s pickup, which had entered the intersection on a green light.
- Plaintiff sued both Alston (uninsured) and Ford for negligence, alleging Ford nevertheless proceeded into the intersection when it was unsafe due to backed-up traffic.
- Ford moved for summary judgment, arguing he was not negligent because he lawfully entered the intersection on a green light and no evidence showed he breached any duty.
- The Superior Court granted summary judgment for Ford; plaintiff appealed, arguing genuine factual disputes remained about whether Ford should have entered the intersection.
- The Supreme Court vacated the grant of summary judgment and remanded, finding credibility conflicts and disputed facts that precluded resolution as a matter of law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ford was entitled to summary judgment on negligence | Williams: Ford entered the intersection when unsafe (traffic backed up) and thus breached duty | Ford: He entered on a green light; no evidence he was negligent or entered unsafely | Vacated summary judgment — factual disputes (credibility, traffic backup) preclude disposition on summary judgment |
| Whether a driver with a green light can still be negligent | Williams: Green light does not absolve responsibility if entry was unsafe | Ford: Green light establishes lawful entry and lack of negligence | Held: Green light does not absolve duty; driver still must exercise care and ensure safe entry |
| Proper standard on summary judgment in negligence cases | Williams: Disputed factual issues (witness/deposition testimony) require trial | Ford: Record lacks evidence to create genuine issue | Held: Summary judgment inappropriate when facts allow more than one reasonable inference; credibility determinations reserved for jury |
| Whether statutory/traffic rules bar negligence claim when entering on green | Williams: Statute and facts support claim that blocking/unsafe entry can be negligent | Ford: Compliance with signal establishes no breach | Held: Statute and precedent require sufficient space and reasonable care; compliance with signal is not dispositive |
Key Cases Cited
- Tri-Town Constr. Co. v. Commerce Park Assocs. 12, LLC, 139 A.3d 467 (R.I. 2016) (summary-judgment review is de novo)
- Plunkett v. State, 869 A.2d 1185 (R.I. 2005) (summary judgment standard and extreme remedy caution)
- Nat’l Refrigeration, Inc. v. Standen Contracting Co., 942 A.2d 968 (R.I. 2008) (view evidence in light most favorable to nonmoving party)
- Hall v. City of Newport, 138 A.3d 814 (R.I. 2016) (duty is question of law; negligence often fact-based and inappropriate for summary judgment)
- DeMaio v. Ciccone, 59 A.3d 125 (R.I. 2013) (credibility conflicts in vehicle-collision cases preclude summary judgment)
- Hefner v. Distel, 813 A.2d 66 (R.I. 2003) (driver approaching intersection must observe traffic and act as a reasonably prudent person)
- Calise v. Curtin, 900 A.2d 1164 (R.I. 2006) (driver with green light still owes a duty to meet a standard of care)