Maryland Accident Law Blog
Causation is an essential part of any Maryland accident case, and in a recent case before a federal appeals court, the court considered whether Apple could be held liable for allegedly causing a devastating car crash. These types of issues can happen in Maryland too. If you have questions, reach out to a dedicated Maryland car accident attorney without delay.
The issue before the federal appeals court was whether a driver’s neurobiological response to a smartphone notification could be the cause-in-fact of a car crash. According to the plaintiffs’ complaint, a woman was driving her car in 2013 when she received a text message on her iPhone. She looked down to read the text message, and when she looked back to the road, she was too late to avoid crashing into another car. The two adults in the other car died, and a child was rendered paraplegic.
Representatives of the victims of the crash sued Apple for negligence and strict products liability. The plaintiffs claimed that the accident was caused by Apple’s failure to warn iPhone users about the risks of distracted driving. The plaintiffs claimed that Apple was at fault because receipt of a text message triggers “an unconscious and automatic, neurobiological compulsion to engage in texting behavior.” Evidently, in 2008, Apple had obtained a patent for “[l]ock-out mechanisms for driver handheld computing devices,” which was meant to address the serious dangers of text messaging while driving. However, Apple did not include any version of the lock-out mechanism on the iPhone 5, the phone the woman was using at the time of the crash.
Apple moved to dismiss the claim, and the judge eventually granted Apple’s motion, and the plaintiffs appealed. The court explained that under state law, negligence requires a showing of proximate cause, which consists of foreseeability and cause-in-fact. Cause-in-fact means that a defendant’s act “was a substantial factor in bringing about the injury which would not otherwise have occurred.” The court explained that being a “substantial factor” was also required for the strict-liability claim.
The court compared the claim to dram shop claims, in which businesses that serve alcohol can be held liable for injury caused by intoxicated customers they served. The court found that the dangers of drinking have been recognized for much longer than the risks of smartphones, and the law makes it a crime only for the driver to read, write, or send a text message while driving. Considering this, the court decided that a smartphone’s effect on a user could not be a substantial factor in the user’s acts under state law. Therefore, the court held that the iPhone could not be a cause in fact, and dismissed the claim.
Causation in Maryland Accident Cases
A plaintiff in any Maryland accident case must prove causation. A negligence claim requires a showing of proximate cause, which is comprised of both “a cause-in-fact” and “a legally cognizable cause.” Cause-in-fact refers to whether the defendant’s conduct caused the injury, and legally cognizable cause refers to whether the defendant should be held liable for the injury, in light of fairness and policy considerations. Cause-in-fact is generally determined by resolving whether the injury would have occurred “but for” the defendant’s conduct. Legal causation often involves determining whether the injury was a foreseeable result of the defendant’s conduct.
Contact a Maryland Accident Attorney
If you have been injured in a serious Maryland car accident, you cannot afford to go it alone or take any chances. The personal injury lawyers at Lebowitz & Mzhen take pride in advocating for the rights of accident victims in and around the Baltimore region. Our attorneys have decades of combined experience and can guide you through each step of the legal process. We aim to reduce the stress on you as much as possible so that you can get your life back on track. For a free consultation, call us at 1-800-654-1949 or contact us online.
More Blog Posts:
Not All Maryland Liability Release Waivers Are Enforceable, Maryland Accident Law Blog, January 2, 2019.
Determining Liability in Maryland Sports Injury Cases, Maryland Accident Law Blog, December 24, 2018.