Reyes v. United States

Background

Whitney Reyes sued the United States over a collision involving a United States Postal Service truck and an Uber vehicle. She alleged that negligence by the postal truck driver caused her physical injury and mental anguish. The opinion first identifies the incident date as June 14, 2019, but its factual discussion states that the collision occurred on May 8, 2018.

According to Reyes’s deposition testimony, she walked around the back of the Uber, opened the passenger door on the side next to moving traffic, entered the vehicle, and began closing the door. The postal truck struck that door. Reyes testified that she did not see the truck before impact and that less than 30 seconds passed from when she walked behind the Uber until the collision. The police report recorded minimal damage to the vehicles and no injuries at the scene, meaning that those involved refused medical attention there. The opinion states that there was no deposition testimony from the postal truck driver, the Uber driver, or the other passenger.

Legal standard

The United States moved for summary judgment under Federal Rule of Civil Procedure 56. Summary judgment is appropriate when the evidence shows no genuine dispute about a fact that matters to the case and the moving party is entitled to judgment as a matter of law. The court must draw reasonable factual inferences in favor of the party opposing the motion, but that party must identify evidence supporting a reasonable jury verdict rather than rely on conclusory assertions.

Because the action was brought under the Federal Tort Claims Act, the court applied New York substantive negligence law. Under that law, a negligence claim requires a duty, a breach of that duty, and causation. New York also permits comparative negligence, meaning that more than one party’s conduct can contribute to an accident and responsibility can be divided. But summary judgment may be granted when the evidence shows that one party’s negligence was the sole proximate cause of the accident or when there is no evidence that the defendant was negligent.

New York Vehicle and Traffic Law § 1214 prohibits opening a vehicle door on the side available to moving traffic unless it is reasonably safe and the act will not interfere with other traffic. The court explained that violating this specific statutory duty constitutes negligence per se, meaning negligence established by the violation itself, unless an applicable excuse or other evidence changes the analysis.

Discussion

The court found that the undisputed evidence established Reyes’s violation of § 1214. She opened the door next to moving traffic, did not see the postal truck, and was focused on entering the Uber and getting to school. The door she opened and was trying to close struck the rear passenger side of the postal truck. The court concluded that these circumstances showed that it was not reasonably safe for her to open the door when she did.

The court acknowledged that the record did not show the postal truck’s speed, where it was when Reyes opened the door, or whether the driver saw her. It nevertheless held that Reyes had the burden to identify evidence from which a reasonable jury could find negligence by the United States or find that she was not the sole proximate cause. The court rejected her speculation that the driver could have seen her and avoided the collision as insufficient evidence.

The court also concluded that the timing evidence did not create a genuine factual dispute. Although Reyes completed the act of opening the door and entered the Uber before the impact, the record did not establish where the truck was when she opened the door or provide a basis for finding that the driver had enough time to see her and avoid the collision. The court therefore determined that Reyes’s conduct was the sole proximate cause of the accident on the evidence before it.

Disposition

Judge Katharine H. Parker granted the United States’ motion for summary judgment. The opinion does not state that the motion was granted with or without prejudice.