Wood v. CRST Expedited, Inc.Annotate this Case
The Supreme Court reversed the district court’s grant of summary judgment in favor of Defendants in this wrongful death action, holding that there were disputed issues of material fact that precluded the district court’s entry of summary judgment.
Plaintiff, on behalf of the estate of the decedent, brought this action against a commercial trucking company and two of its drivers, alleging that the drivers illegally and negligently parked a semi tractor-trailer in an I-80 emergency lane, causing the vehicle the decedent was driving to collide with the tractor-trailer and the decedent to suffer immediately fatal injuries. Defendants asserted that they were entitled to summary judgment as a matter of law because Plaintiff did not prove that parking on the shoulder of the highway caused the decedent to lose control of his vehicle. The district court granted the motion for summary judgment. The Supreme Court reversed, holding that the district court did not apply the proper standard and that Plaintiff must prove instead that the act of parking on the shoulder of an interstate highway created a reasonably foreseeable increased risk of injury to the decedent. Accordingly, the proximate cause issue should be resolved by the jury.