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plaintiffdefendantnegligenceappealtrialverdictpleamotion

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Snell v. Norwalk Yellow Cab, Inc., 332 Conn. 720, 212 A.3d 646

Facts

Brenda Snell was injured when she was struck by a taxicab stolen by two teenagers after the driver, Johnley Sainval, left the vehicle unattended with the keys in the ignition in a high-crime area. The teenagers, having consumed alcohol and drugs, took the cab for a joyride, during which they crashed into another vehicle and then drove onto the sidewalk, hitting Snell. The jury found Sainval negligent for leaving the keys in the ignition but also found that the accident was outside the scope of the risk created by his negligence, leading to the defendants' verdict.

The plaintiff initially commenced this action solely against Sainval and Yellow Cab. Johnson and Bowden were not named by the plaintiff as defendants in the civil action. Although the defendants filed an apportionment complaint against the two teens, the court later granted the plaintiff's motion to strike the apportionment complaint, agreeing with the plaintiff that apportionment was unavailable in the present case because the misconduct of the teenagers was not pleaded as mere negligence but as reckless or intentional conduct.

Issue

Did the Appellate Court correctly determine that the doctrine of superseding cause applies in cases where the conduct of a third party is criminally reckless, and did it properly deny the plaintiff's motion to set aside the verdict?

Did the Appellate Court correctly determine that the judgment of the trial court should be affirmed on the basis that the doctrine of superseding cause applies in cases in which the conduct of a third party is criminally reckless?

Rule

The doctrine of superseding cause applies to criminally reckless conduct, and a jury can find that a defendant's negligence is a proximate cause of an injury while also determining that the intervening actions of a third party were a superseding cause.

The doctrine of superseding cause applies to criminally reckless conduct, but jury's responses to interrogatories, in which it found both that driver's negligence was proximate cause of pedestrian's injuries and that actions of thieves were superseding cause of injuries, were not legally consistent.

Analysis

The court analyzed the jury's findings and the instructions given regarding proximate cause and superseding cause. It noted that while the jury found Sainval's negligence to be a proximate cause of Snell's injuries, it also found that the actions of the thieves were a superseding cause, which created a legal inconsistency. The court emphasized that the jury's determination of foreseeability and the scope of risk were critical in assessing the relationship between Sainval's actions and the resulting injuries.

The court found that there was no basis for concluding that it should not have submitted the doctrine of superseding cause to the jury in this case or that the resulting verdict and interrogatories were fatally inconsistent.

Conclusion

The Supreme Court reversed the Appellate Court's judgment, concluding that the jury's findings were legally inconsistent and remanded the case for further proceedings.

The Supreme Court, Palmer, J., held that: 1 doctrine of superseding cause applies to criminally reckless conduct, but 2 jury's responses to interrogatories, in which it found both that driver's negligence was proximate cause of pedestrian's injuries and that actions of thieves were superseding cause of injuries, were not legally consistent.

Who won?

The defendants prevailed in the case because the jury found that the actions of the thieves constituted a superseding cause, relieving Sainval of liability despite finding him negligent.

The Appellate Court rejected the plaintiff's claims; id., at 41–42, 158 A.3d 787; and we granted the plaintiff's petition for certification to appeal, limited to the following issues.

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