Williams v. Samek Trucking

Background

Tariq Williams sued Samek Trucking, Michael Samek, and Eric Young for damages arising from a February 20, 2020 motor vehicle accident. Williams alleged that, while he was driving a Toyota Camry on 95 North near the Yankee Stadium exit, the defendants’ truck struck his vehicle from behind. He alleged that the defendants were negligent in the ownership and operation of the vehicle.

The defendants moved for summary judgment under Federal Rule of Civil Procedure 56. Summary judgment is a decision without a trial that is appropriate when the evidence shows no genuine dispute about a fact that could affect the outcome and the moving party is entitled to judgment under the law.

The Parties’ Accounts

Williams testified that he had been traveling in the same lane for several minutes and did not try to merge before the accident. He said Young’s truck was traveling faster than his car, made heavy contact with the rear of his car, and scraped along its side as it passed. Williams said his car was propelled forward but did not hit another vehicle.

Young gave a different account. He testified that traffic was stopped or moving only slightly and that his truck was stationary or nearly stationary when he heard a horn and felt Williams’s car drag across the front of the truck. The defendants characterized the collision as a side-swipe caused by Williams’s unsafe lane change.

Arguments on Summary Judgment

The defendants argued that Williams’s account was impossible to believe and that Young’s testimony, together with a report by accident reconstructionist Robert Genna, showed that Williams’s unsafe lane change violated New York Vehicle and Traffic Law § 1128 and was the accident’s sole proximate cause.

Williams argued that the parties’ differing testimony presented questions of fact and credibility for a jury. He disputed that he changed lanes and argued that Genna’s opinion was not factual and should not be accepted or considered at that stage.

Court’s Analysis

Under New York negligence law, a plaintiff must show a duty, a breach of that duty, and that the breach was a proximate cause of the damages. The court explained that negligence and causation in vehicle-collision cases generally present factual and credibility questions for a jury, especially when the parties offer sharply conflicting accounts.

The court held that genuine disputes of material fact remained. The defendants did not dispute that Young’s vehicle contacted Williams’s vehicle, and photographs showed substantial damage to the rear and side of Williams’s car. The remaining circumstances—including each vehicle’s speed, whether Williams changed lanes, whether Young’s truck struck Williams’s car from behind, and which driver caused the collision—were sharply disputed.

The court also rejected the argument that Genna’s report made Williams’s account impossible as a matter of law. Even assuming the report was admissible, the court found that it mainly supported the defendants’ version and identified a lack of evidence corroborating Williams’s version; it did not conclusively establish that Williams’s account could not have occurred. Because Williams disputed changing lanes, a reasonable juror could find that he did not violate Section 1128 and was not negligent as a matter of law.

The court did not decide whether Genna’s report was admissible. It reserved that issue for any motion at or before trial.

Ruling

Judge Lewis J. Liman denied the defendants’ motion for summary judgment and directed the Clerk of Court to close Docket Number 15. The order did not decide which account of the accident was correct or whether any defendant was ultimately liable.