Motor Vehicle Accident: Haag v. Adams (N.Y. Sup. Ct., Onondaga Co.)
December 31, 2017
In Haag, there were two competing versions of the facts as to a three-car accident that occurred on Route 481-S near Syracuse, New York. According to the the driver of the middle car, plaintiff Ms. Haag, she was initially able to bring her vehicle to a stop behind the first vehicle driven by Ms. Granzow, and was only propelled into Ms. Granzow’s vehicle when rear-ended by the rear-most car driven by defendant Mr. Adams. However, Mr. Adams testified that Ms. Haag was involved in a large rear-end collision with Ms. Granzow, that his vehicle was hit with debris from that first accident, and that he was unable to avoid striking the rear-end of Ms. Haag’s vehicle. Although Mr. Adams admitted he did strike the rear-end of Ms. Haag’s vehicle, he stated this was a minor impact and that he was only going a few miles an hour at the time. Ms. Granzow was dismissed from the case upon dispositive motions.
At a bifurcated negligence-only trial, the Supreme Court, Onondaga County, heard testimony from all three drivers, as well as from the responding police officer. Plaintiff’s accident reconstruction expert, Mr. Camerato, then testified that due to the damage patterns of each vehicle, plaintiff’s version of the events was the more likely scenario. Defendant’s consulting accident reconstruction expert, Mr. Puckett, reviewed Mr. Camerato’s reports and ran the various scenarios in his own system, assisting in defendant’s cross-examination of Mr. Camerato. After hearing all of the proof, the jury returned a unanimous verdict that Mr. Adams was not negligent. Since Mr. Adams admitted he struck the rear-end of the middle vehicle operated by Ms. Haag, it appears the jury accepted Mr. Adams’ defense based on the emergency doctrine — i.e., that there was a large collision between the first and second vehicles and that Mr. Adams could not avoid colliding with the second vehicle due to the sudden nature of the first impact and the debris that hit Mr. Adams’ vehicle.