George Ready, II v. RWI Transportation, LLC
203 So. 3d 590
| Miss. | 2016Background
- Two separate accidents on I-55 N in Grenada County on May 24, 2012: an initial collision at 7:13 p.m. involving Williams (tractor-trailer leased to RWI) and Spurlock that left Spurlock’s overturned truck partially blocking both northbound lanes on a bridge; Williams parked on the east shoulder north of the bridge.
- Police (Officer Willis) arrived, closed northbound lanes, and reopened them at ~8:09 p.m.; traffic was backed up as a result of the Williams–Spurlock accident.
- About 55 minutes after the first accident and roughly 3/4 mile south of it, Ready rear-ended a stopped UPS tractor-trailer in backed-up traffic at ~8:21 p.m., sustaining injuries.
- Defendants (RWI and Williams) moved for summary judgment arguing Ready’s injuries were not a foreseeable consequence of Williams’s accident and thus no duty was owed; supporting witnesses testified weather/visibility were good and Ready was driving 65–70 mph and attempted to brake/swerve too late.
- Trial court granted summary judgment for RWI/Williams finding the first accident was too remote in time and distance to impose a duty; Mississippi Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants owed Ready a duty because Ready's injuries were a foreseeable result of Williams's accident | Ready: the first accident foreseeably caused traffic backup and thus subsequent collisions, so duty exists | RWI/Williams: the later collision was remote in time (≈55 min) and distance (≈3/4 mile); not foreseeable, so no duty | Court: No duty; first accident too remote in time/distance to be a foreseeable legal cause |
| Whether defendants' negligence was a proximate cause of Ready's injuries | Ready: Williams's negligence proximately caused the traffic conditions leading to Ready's collision | Defendants: intervening events/other drivers’ conduct superseded any causal chain from Williams | Court: Original negligence, if any, was a remote, nonactionable cause; not proximate |
| Whether summary judgment was inappropriate because causation/time/distance are jury questions | Ready: issues of negligence and causation should be decided by a jury | Defendants: undisputed facts show remoteness as a matter of law | Court: Duty (foreseeability) is a question of law here; summary judgment appropriate |
| Whether Ready was negligent as a matter of law | Ready: argued negligence is factual and for jury | Defendants: testimony showed Ready driving too fast and failing to avoid stopped truck | Court: Ready offered no contrary affidavit; factual circumstances supported summary judgment for defendants on duty/causation, rendering claim nonactionable |
Key Cases Cited
- Harris v. Darby, 17 So. 3d 1076 (Miss. 2009) (standard of review for summary judgment)
- Huynh v. Phillips, 95 So. 3d 1259 (Miss. 2012) (elements of negligence and summary judgment standards)
- Robison v. McDowell, 247 So. 2d 686 (Miss. 1971) (original negligent act is nonactionable if remote and superseded by an independent intervening cause)
- Hoke v. W. L. Holcomb & Assocs., Inc., 186 So. 2d 474 (Miss. 1966) (distinguishing mere occasion or condition from proximate causation)
- Mississippi City Lines, Inc. v. Bullock, 13 So. 2d 34 (Miss. 1943) (same principle on remoteness and nonactionable causes)
- Permenter v. Milner Chevrolet Co., 91 So. 2d 243 (Miss. 1956) (original negligence too remote to be regarded as cause)