419 P.3d 503
Wyo.2018Background
- At ~6:45 a.m. on Feb. 11, 2014 a CRST tractor-trailer was stopped and parked in the I‑80 emergency lane near Rawlins, WY; portions were within 10 inches of the eastbound lanes and hazard lights were on.
- The driver, Chavez, stopped because he felt drowsy and intended to change drivers; parking signs prohibited non‑emergency stops; Chavez received a citation for illegal parking.
- Minutes after the stop, David Crashley (decedent) driving a Mazda at near‑highway speeds collided with the rear of the parked trailer in the emergency lane and died; there were no skid marks or evidence of avoidance.
- Plaintiff (Misty Wood, personal representative) sued CRST and the drivers for wrongful death alleging negligence in illegal parking and vicarious liability; defendants moved for summary judgment arguing the parking was not a proximate cause.
- The district court granted summary judgment for defendants, finding the parking did not cause the decedent to leave the travel lanes; the Wyoming Supreme Court reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether disputed material facts precluded summary judgment on proximate cause | Chavez's illegal parking created a foreseeable, substantial risk of the type of harm that occurred (parked massive obstacle near lanes) | Parking did not cause decedent to leave lane; absent proof parking caused loss of control, parking is not proximate cause | Reversed: proximate cause is a foreseeability/substantial‑factor inquiry for jury; disputed facts exist |
| Whether plaintiff had to prove parking caused decedent to lose control | No; plaintiff must show parking increased a reasonably foreseeable risk and was a substantial factor | Yes; plaintiff must show parking caused decedent to leave lanes | Held for plaintiff: causation need not show parking caused loss of control, only that it was a proximate cause via foreseeability/substantial factor |
| Whether statutory violation (illegal parking) establishes duty/foreseeability | Statute and no‑parking signs support a duty to motorists and make harm foreseeable | Statutory violation alone is insufficient; decedent's independent act severs causation | Court: statutory violation is evidence of negligence and bears on duty/foreseeability; factual disputes remain |
| Whether decedent's unexplained departure from lane is an unforeseeable intervening/superseding cause | Plaintiff: such departures (sleep, medical event, distraction) are foreseeable risks that make parking negligent | Defendant: decedent's conduct was an independent, unforeseeable intervening act that severs causation | Court: reasonable minds could differ whether intervening act was foreseeable; leave to jury |
Key Cases Cited
- Cabral v. Ralphs Grocery Co., 51 Cal.4th 764 (Cal. 2011) (truck parked alongside freeway can create foreseeable risk and be a proximate cause; duty not categorically excluded)
- Lucero v. Holbrook, 288 P.3d 1228 (Wyo. 2012) (proximate cause requires conduct be a substantial factor; duty and foreseeability analysis)
- Amos v. Lincoln Cty. Sch. Dist. No. 2, 359 P.3d 954 (Wyo. 2015) (questions of proximate and intervening cause for jury when reasonable minds may differ)
- Kopriva v. Union Pac. R.R., 592 P.2d 711 (Wyo. 1979) (original negligent act may be only remote cause if it merely furnishes condition or occasion)
- Buckley v. Bell, 703 P.2d 1089 (Wyo. 1985) (trial‑finder may determine whether intervening acts are foreseeable; not all consequences are proximate)
- Beesley v. United States, 364 F.2d 194 (10th Cir. 1966) (proximate cause requires an efficient causal chain; subsequent independent acts can be superseding)