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Who is at Fault for a Chain Reaction Collision on Alabama I-65?

picture of a car wreck pileupIf you have ever been involved in a chain reaction collision, you know how frightening and dangerous they can be. If you are lucky enough to just be reading about a pile up, you may have thought to yourself: “Who is at fault in a chain reaction collision?” The question is complicated under Alabama law, and you are going to need to hire skilled and talented Huntsville auto accident attorneys.

Car Accidents in Huntsville: Legal Basics

Liability for car accidents is governed by the Alabama law of negligence. In order to establish a negligence claim, a plaintiff, the person injured in the accident, must prove:

A duty to a foreseeable plaintiff;

A breach of that duty;

Proximate causation; and

Damage or injury.

With respect to chain reaction collisions, often the hotly contested legal issue is the element of causation. Take the case of Miller v. Cleckler, 51 So. 3d 379 (Ala. Court of Civil Appeals 2010). That case involved four cars driven by Mr. Cleckler, Mr. Miller, Mrs. Miller, and Mr. Williams. The four-car pile up occurred on I-65 in Shelby County on a sunny Friday afternoon in the summer of 2006. Mr. and Mrs. Miller were in two separate cars following each other with Mr. Miller in front. Cleckler was driving a white pickup truck and Williams was in a vehicle behind Mrs. Miller. Cleckler was accused by witnesses of “darting” through traffic “at a high rate of speed” “trying to pass everyone.”

At some point, Cleckler moved in front of Mr. Miller’s car. Cleckler testified that, shortly after moving into the lane in front of Mr. Miller, the vehicles in front of him began to brake, causing him to apply his brakes “pretty good” as he said. By contrast, Mr. Miller claimed that Cleckler “slammed on his brakes.”

Either way, when Cleckler started braking, Mr. Miller and Mrs. Miller began to brake, as well. At that point, Williams’s vehicle struck Mrs. Miller’s vehicle from behind, causing her vehicle to collide with the back of her husband’s vehicle, which, in turn, collided with the back of Cleckler’s pickup truck. Mrs. Miller testified that her vehicle was not in danger of colliding with Mr. Miller’s vehicle before Williams struck her from behind. Mrs. Miller suffered injury and sued both Williams and Cleckler for negligence.

Madison County: Debating Causation

In this real-life example, assuming that Mr. and Mrs. Miller were driving properly, there are two possible guilty parties: Cleckler and Williams. Normally, Williams would be liable because the law requires him to keep a safe distance behind the vehicle in front of him.

Section 32-5A-89(a), Ala.Code 1975, provides:

“(a) The driver of a motor vehicle shall not follow another more closely than is reasonable and prudent, having due regard for the speed of such vehicles and the traffic upon and the condition of the highway. Except when overtaking and passing another vehicle, the driver of a vehicle shall leave a distance of at least 20 feet for each 10 miles per hour of speed between the vehicle that he is driving and the vehicle that he is following.”

Clearly, Williams did not follow the law and, as such, breached his duty of care.

However, in this case, Williams can point the finger at Cleckler and say that Cleckler was the cause of the accident because, if Cleckler had not be driving recklessly, darting in and out of lanes, no one would have applied their brakes and Williams would not have needed to stop.

In fact, this is true. Cleckler might be have caused the accident since he was violating his duty to drive carefully and with due care. But, like Williams, Cleckler can try and deflect liability by saying that Williams was the real cause since both Mr. and Mrs. Miller would not have hit Cleckler’s pickup but for the fact that Williams was following too close.

In the actual case of Miller v. Cleckler, the Alabama Court of Civil Appeals was responding to legal issues and the court sent the case back to the trial court to have a jury decide the facts. As the court said: “[t]ypically, the question of proximate causation is a question of fact to be resolved by the jury; that question must be decided by the jury if reasonable inferences from the evidence support the plaintiff’s claim.”

Possible Resolution

We do not know how the case turned out. Very likely, the case reached a settlement. More than 90% of Huntsville and Alabama cases settle before reaching a jury.

But, from the facts that we know, Williams is the likely guilty party, particularly if he saw or should have seen Checkler’s aggressive driving. Under the law, causation includes all the foreseeable events that flow from your breach of duty. Williams was following too close and the chain reaction collision was foreseeable from his actions. Thus, he is likely liable for hitting Mrs. Miller’s car, for her subsequent collision with Mr. Miller’s car and then Mr. Miller’s collision with Cleckler’s pickup truck. If he saw Cleckler “darting in and out of traffic,” then Williams was duty-bound to slow down and given even more distance between himself and Mrs. Miller.

As for deflecting the blame from himself to Cleckler, the problem for Williams is that Cleckler’s “bad behavior” came before his. Thus, Williams’ breach of duty — following too close — is likely an “intervening cause” that relieved Cleckler of liability.

Contact Our Huntsville, Alabama Accident and Personal Injury Lawyers

As you can see, figuring out who is at fault in a pile up accident is complicated. The legal doctrine of “intervening causation” is complex and fact-dependent. Moreover, we assumed for this discussion that Mr. and Mrs. Miller were completely innocent, but that is not always the case. In a pile up accident, each person might have some degree of carelessness that contributed to the crash.

If you or someone you love has been injured or killed in a chain reaction collision in Madison County or anywhere else in Alabama, contact an experienced Huntsville and Madison County personal injury and accident attorney like the ones at Hornsby, Watson, Hornsby & Heyward. Call today. You can email us or call (256) 414-9803, toll free (866) 986-1371. These cases require attention to detail, experience, and knowledge of Alabama auto accident laws. Hornsby, Watson, Hornsby & Heyward is committed to helping injured Huntsville motorists recover the compensation to which they are entitled. Consider Hornsby, Watson, Hornsby & Heyward to be YOUR Huntsville auto accident law firm.


Our personal injury attorneys in Huntsville, AL are proud of the accomplishments and results we have obtained over more than a century of combined experience. We remain committed to our roots as a client-focused personal injury law firm, however, and every client — beginning when they meet with us for the first time in a private, no-cost and no-obligation consultation.

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