California Appellate Court Discusses the Sudden Emergency Doctrine in Recent Road Rage Case

Earlier this year, a state appellate court issued an opinion in a California car accident case discussing the sudden emergency doctrine. Ultimately, the court concluded that the defendant driver was not liable for the plaintiff’s injuries because her actions that led to the collision were in response to a sudden emergency.

The Sudden Emergency Doctrine

Under California law, a motorist can be held liable for any injuries that are the natural result of their negligence. However, under the sudden emergency doctrine, a defendant’s actions may be excused if the defendant “acting with reasonable care, is suddenly and unexpectedly confronted by an emergency he did not cause.”

The Facts of the Case

According to the court’s opinion, the plaintiff was in a line of cars that were entering Highway 101. As the vehicles approached the end of the onramp, one of the cars entered the highway and sped past the rest of the line, making an obscene gesture to the motorist at the front of the line. Shortly after this, the car that had just passed the other cars slammed on the brakes, causing the other vehicles in the line to slow down.

Evidently, the plaintiff was driving the third car in the line, and was initially able to come to a complete stop. However, the defendant truck driver was behind the plaintiff, and was unable to stop in time. The defendant’s truck rear-ended the plaintiff’s car, pushing it into another vehicle. The motorist who slammed on his brakes entered the highway and was not located. The plaintiff filed a personal injury lawsuit against the defendant truck driver, claiming that the defendant was negligent in rear-ending his car.

The Court’s Opinion

The court explained that a defendant must be able to establish three elements to be entitled to the benefit of the sudden emergency doctrine:

• That there was a sudden and unexpected emergency situation in which someone was in actual or apparent danger of immediate injury;
• That the defendant did not cause the emergency; and
• That the defendant acted reasonably, even if it there may have been a better course of action in hindsight.

The court held that the defendant met all three elements and dismissed the plaintiff’s case. The court explained that the motorists could not be expected to foresee that another driver will slam on the brakes as they are entering the highway. The court then held that, given the situation that the defendant was confronted with, his actions in sounding the horn and attempting to come to a complete stop were reasonable.

Have You Been Injured in a California Car Accident?

If you or a loved one has recently been injured in a California car accident, you may be entitled to monetary compensation. At the Neumann Law Group, we represent injury victims in a wide range of California personal injury claims, including car and truck accidents. We have over 200 years of experience advocating on behalf of the injured, serving clients in the Los Angeles and Orange County areas. To learn more about how we can help you recover for your injuries, call 800-525-NEUMANN to schedule your free consultation today.

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