Single Car Accidents and Third-Party Liability – O’Malley v. Ranger Construction Industries

In O’Malley v. Ranger Construction Industries, Florida’s Fourth District Court of Appeals considers a single car accident case in which the injured motorist didn’t blame other drivers for the crash, but instead pointed the finger at an allegedly negligent road construction company.

Mr. O’Malley was injured in a single-car accident in Florida while driving on I-95. The accident occurred at dusk, and the Court said it was raining and had been raining most of the day. He later sued Ranger Construction, the company responsible for maintaining the stretch of road where the accident occurred. He alleged that the company was negligent in failing to remove standing water from the highway and to provide adequate drainage.
He also said the company failed to warn him of the hazardous standing water on the road.

The only witness to the accident, a driver who was in the far right lane of the highway at the time, said O’Malley was in the far left lane at the time of the crash and appeared to be traveling too fast, given the conditions. A state trooper who later arrived on the scene testified that he saw standing water in the road near where the accident occurred. The trooper prepared an accident report indicating that O’Malley was driving too fast and the accident happened when he came in contact with the slick surface.

A trial court granted summary judgment to Ranger, finding that a jury couldn’t return a verdict for O’Malley on his claims. Specifically, the trial judge said such a verdict would require the impermissible “stacking” of these inferences: 1) there was a puddle or area of standing water in O’Malley’s lane at the time of the accident; 2) O’Malley’s vehicle came into contact with the water; and 3) this caused the accident. The judge said there was no direct evidence to support these inferences and that each inference didn’t exclude other inferences. The Court also found adequate evidence to support Ranger’s argument that O’Malley caused the accident by speeding.

Reversing the decision on appeal, the Fourth District ruled that O’Malley wasn’t required to rule out all other inferences about the cause of the accident at the summary judgment stage. “Ranger has taken what is essentially one inference – that the standing water caused the accident – and attempted to stretch it out into multiple inferences,” the Court said. “Where there is only one inference relating to causation, the non-movant to the motion for summary judgment does not have to establish that the sole inference is the only reasonable inference.”

Here, the Court said the parties agreed that the standing water was a cause of the accident. Whether O’Malley’s alleged speeding contributed to the crash remained to be seen.

As this case makes clear, other drivers aren’t necessarily the only responsible parties in Florida car accident cases. If you or a loved one has been injured in an accident in Florida, contact the South Florida car accident lawyers at Anidjar & Levine. From offices in Ft. Lauderdale, we serve clients throughout the area, including in Boca Raton, Coral Springs and Pompano Beach.

Related blog posts:

Florida Court Says Automaker May be Liable for Single-Car Accident – Rooker v. Ford Motor Company

Federal Court Retains Jurisdiction in Single-Car Rollover Accident Case -Small v. Ford Motor Company

Causation Requirement in Florida Car Accident Lawsuits – Hernandez v. Gonzalez