Simler v. Dubuque Paint Equipment Services, Inc., No. 18-3315 (8th Cir. 2019)Annotate this Case
A driver who causes an accident on a highway is not liable for a second one occurring in the traffic backup that follows. The Eighth Circuit applied Missouri law and held that the backup along the interstate did not lead the driver in the second accident to drive too fast or limit his ability to see the traffic ahead. Nor was it foreseeable that another accident would occur under these circumstances—eight-or-more minutes later in a spot nearly half a mile back—when every driver before the driver in the second accident had managed to stop. In this case, the court held that the causal chain stops with the driver in the second accident, not the driver in the first accident. Accordingly, the court affirmed the district court's grant of summary judgment to the driver in the first accident.