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Thursday, February 09, 2012

Ind. Decisions - 7th Circuit draws line on proximate cause, at least in Illinois

In David Blood v. VH-1 Music First, an 11-page opinion, Judge Kanne writes:

Dennis Hernandez caused a severe automobile accident in Southern Illinois that closed northbound I-57 for several hours. The resulting traffic jam stretched at least four and one-half miles. With traffic still not moving four hours later, truck driver Milinko Cukovic rear-ended David Blood’s vehicle. Among others, Blood brought a personal-injury suit against Hernandez and several related entities on the theory that Hernandez proximately caused the second accident. Unconvinced, the district court entered summary judgment for Hernandez and the other defendants. We affirm. * * *

We recognize, as did Justice Frankfurter in his Pearce v. Comm’r dissent, that “[i]n law as in life lines have to be drawn,” 315 U.S. 543, 558 (1942), and drawing a line for purposes of proximate cause is no different, see W. Page Keeton, et al., Prosser and Keeton on the Law of Torts § 41, p. 264 (5th ed. 1984) (“As a practical matter, legal responsibility must be limited to those causes which are so closely connected with the result and of such significance that the law is justified in imposing liability. Some boundary must be set to liability for the consequences of any act . . . .”). In Illinois, we duly recognize that drawing the line for proximate cause is usually a task for the factfinder. But, this case presents a set of facts nowhere near that line. To allow this case to continue beyond summary judgment opens the door to endless liability, such that the first wrongdoer in a highway accident will forever be liable to all other drivers that follow. This is plainly a result that proximate cause analyses are designed to avoid. Thus, we find, as a matter of law, that the Hernandez defendants did not proximately cause Blood’s injuries and reasonable jurors “could not differ as to the inferences to be drawn from those facts.” Harrison, 758 N.E.2d at 854.


We hold that the Hernandez defendants did not proximately cause David Blood’s injuries, and as such we AFFIRM the district court’s grant of summary judgment for the defendants.

Posted by Marcia Oddi on February 9, 2012 03:42 PM
Posted to Ind. (7th Cir.) Decisions