The California Court of Appeals recently rendered a decision in a case, Kaiser v. Sports Car Racing Association of the Monterey Peninsula, Cal. Ct. App. (2015), that dealt with an appeal from a case involving a fatal motorcycle collision.
The plaintiff’s husband was involved in a motorcycle accident following an event that thousands of motorcycle enthusiasts attended at the Mazda Laguna Seca Raceway, which is located in an unincorporated area of Monterey County.
Directly after the event, the plaintiff’s husband was struck by several motorcycles that had collided and slid into his lane. The plaintiff’s husband reportedly overturned and struck the ground several times before coming to rest in a field. The decedent was pronounced dead at the scene.
The plaintiff filed a wrongful death action against SCRAMP and others, alleging negligence in regard to the traffic control plan for the event, which forced all of the motorcyclists to travel on the road where the accident occurred, which resulted in a large amount of motorcyclists having to make u-turns in front of a blind curve, creating a potentially dangerous situation. The corpus of the negligence claim was related to the development and implementation of the traffic flow plan following the event.
The defendant SCRAMP moved for summary judgment, to which it attached several exhibits illustrating the location of the raceway, the relevant roadways, a copy of the traffic control plan, and testimony from a CHP officer regarding the event.
The CHP officer’s testimony stated that he had overseen the event and coordinated the traffic control issues related to the location. He was also the coordinator at the time of the event.
At trial, the plaintiff’s counsel argued that SCRAMP controlled the roadway and that it should have put certain signs into place to direct traffic better. The defendant’s counsel stated that the traffic plan that SCRAMP had adopted was approved by all the relevant government agencies, and that the accident was caused by the other rider’s “crazy U-turn.”
The trial court agreed with the defendant SCRAMP, finding no evidence that the motorcyclists did not know how to get where they were going, that the accident was caused by the other motorcyclist, and that SCRAMP had no duty beyond what it had done. The court therefore granted the summary judgment motion.
The plaintiff then appealed, arguing that SCRAMP did exercise control over the road where the accident took place, and that it was the lack of signs regarding where riders should have gone and to reduce speed, etc. that was responsible for creating the dangerous situation. The plaintiff argued that the accident was thus foreseeable.
The Court of Appeals thus began the discussion with a statement regarding the relevant standard of proof required in negligence cases. In order to prevail on a negligence cause of action, the plaintiff must demonstrate: “(1) the defendant’s legal duty of care towards the plaintiff, (2) the defendant’s breach of that duty, (3) injury to the plaintiff as a proximate result of the breach, and (4) damage to the plaintiff.”
Regarding the necessary duty element, the court reviewed the relevant laws regarding who controls the roads, and it determined that the roads are controlled by the state. Case law explicitly states that roads are not controlled by cities, and therefore, by a natural extension of that logic, SCRAMP could not have had control over the relevant road. Courts have rejected similar arguments alleging a duty in cases of residential buildings and businesses where individuals are injured on adjacent streets.
The court found that the plaintiff’s allegations were not sufficiently distinguishable from the other cases in which the courts failed to find a duty. Therefore, the court of appeals agreed with the trial court’s decision granting the motion for summary judgment. The judgment was thus affirmed.
If you were injured or a loved one was killed in a Riverside motorcycle wreck, let our experienced attorneys bring a lawsuit on your behalf against the responsible parties. We represent motorcycle accident victims in Rancho Cucamonga, Temecula, and San Bernardino. Contact us at 1-866-422-7222 or via our online form for a free, no-obligation consultation.
More Blog Posts:
California Court of Appeals Clarifies Foreign Body Language for Medical Malpractice Claims, Southern California Injury Lawyer Blog, published June 19, 2015
California Court of Appeals Upholds Evidentiary Ruling in Grocery Store Slip & Fall Case, Southern California Injury Lawyer Blog, published June 17, 2015