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Dalal v. City of New York

Supreme Court, Queens County
692 N.Y.S.2d 468 (1999)
ELI5:

Rule of Law:

An unexcused violation of a statutory standard of care, such as operating a motor vehicle in violation of a license restriction requiring corrective lenses, constitutes negligence per se.


Facts:

  • Alicia Ramdhani-Mack's New York State driver's license contained a restriction requiring her to wear corrective lenses while driving.
  • Ramdhani-Mack was nearsighted and required prescription glasses.
  • While driving, Ramdhani-Mack was not wearing her corrective lenses.
  • The plaintiff stopped his vehicle at a stop sign at the intersection of 66th Avenue and Booth Street.
  • After looking both ways and seeing no oncoming traffic, the plaintiff proceeded into the intersection.
  • Ramdhani-Mack's vehicle, traveling on Booth Street, struck the driver's side of the plaintiff's vehicle within the intersection.
  • The plaintiff testified that he never saw Ramdhani-Mack's car before the impact.
  • Ramdhani-Mack testified she first saw the plaintiff's vehicle when she was 10 to 15 feet from the intersection but could not avoid the collision.

Procedural Posture:

  • The plaintiff filed an action against Alicia Ramdhani-Mack in the Supreme Court, Queens County (trial court) to recover damages for personal injuries from an automobile accident.
  • The case was tried before a jury.
  • The jury returned a verdict finding that the defendant, Alicia Ramdhani-Mack, was not negligent.
  • Based on the verdict, the trial court entered a judgment in favor of Ramdhani-Mack, dismissing the plaintiff's complaint.
  • The plaintiff (appellant) appealed the judgment to the appellate court.

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Issue:

Does a driver's unexcused violation of a license restriction requiring the use of corrective lenses while operating a motor vehicle constitute negligence per se?


Opinions:

Majority - Ritter, J. P., Joy, Goldstein and Schmidt, JJ.

Yes. An unexcused violation of a license restriction requiring corrective lenses constitutes negligence per se. The court reasoned that while operating a vehicle without a license is not negligence per se because it relates to the authority to drive, a restriction requiring glasses directly relates to the manner of the vehicle's actual operation. Vehicle and Traffic Law § 509 (3) establishes a statutory standard of care. Citing Martin v Herzog, the court held that an unexcused violation of such a standard is negligence per se. Therefore, the trial court erred by refusing to instruct the jury on this principle and by preventing cross-examination on the license restriction, as it was relevant to both Ramdhani-Mack's ability to see and the issue of negligence.



Analysis:

This decision clarifies a key distinction in tort law between administrative statutory violations and those that set a standard for safe conduct. It establishes that a violation of a driver's license restriction directly related to safe operation (e.g., wearing glasses) is negligence per se, not merely evidence of negligence. This precedent lowers the burden for plaintiffs in similar cases, as they no longer need to prove that the failure to adhere to such a restriction was unreasonable, only that the violation occurred and was a proximate cause of the injury. It reinforces the importance of specific jury instructions regarding statutory violations that directly impact the manner of a vehicle's operation.

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