Yes, the drivers from the first crashes can still be blamed. The court explained that just because a lot of time passed, it doesn't automatically get the first drivers off the hook. Their actions created the dangerous traffic jam in the first place. The court said it should be up to a jury to decide if the first crash was a 'substantial factor' in causing the final injuries. A rear-end collision in a massive, stopped-traffic situation isn't so 'highly extraordinary' or weird that it breaks the chain of blame. It's a foreseeable risk created by the original accident.

Yes, the lower court made a mistake about who caused the accident. Just because two hours passed doesn't mean the earlier actions stopped being important in causing the crash. Regular people on a jury should get to decide if those actions were still important. The court also shouldn't have decided on its own that the delivery truck driver's actions were the only important cause. There are facts that people disagree about, so a jury should decide that too. But the court was right to say the police can't be sued. The people suing didn't show that their case fits into any of the special situations where the police can be sued. The road condition wasn't caused by the government's property, and there's no proof the police drove their cars carelessly.

No. The passage of two hours and the subsequent negligent act of a third driver do not, as a matter of law, constitute a superseding cause that relieves the original negligent actors of liability. The determination of whether an actor's conduct was a substantial factor in causing an injury, and whether an intervening act was a superseding cause, are questions of fact for the jury. The court adopted the 'substantial factor' test from the Restatement (Second) of Torts § 431, which considers factors such as the lapse of time and whether the actor's conduct created a continuous force. Citing § 433, the court reasoned that 'mere lapse of time, no matter how long' does not sever causation if the original negligence remains a substantial factor. Furthermore, under § 447, an intervening negligent act is not a superseding cause if it was a foreseeable consequence of the situation created by the original actor or was not 'highly extraordinary.' Since reasonable individuals could differ on whether the defendants' actions were a substantial factor and whether Questore's subsequent negligence was highly extraordinary, the trial court erred in granting summary judgment.

Yes, the trial court erred in granting summary judgment on the proximate cause issue. The mere lapse of two hours between the initial accidents and the plaintiffs' injuries does not preclude finding that the defendants' conduct remained a substantial factor in causing the harm. A jury could reasonably differ on whether the defendants' actions were a substantial factor, so summary judgment was improper. The trial court also erred in concluding as a matter of law that Questore's conduct was a superseding cause. There are disputed issues of material fact regarding Questore's actions that a jury should properly resolve. However, the trial court correctly granted summary judgment for the PSP based on sovereign immunity. The plaintiffs failed to establish that their claims fall within any of the statutory exceptions to immunity. The condition of the highway did not originate from Commonwealth realty as required for the real estate exception. And there was no evidence the PSP negligently operated their vehicles as required for the vehicle liability exception.

Taylor v. Jackson

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