In a case involving a fatal car accident, the Appellate Division addressed whether a driver who admitted to falling asleep at the wheel could be found negligent as a matter of law. The lower court denied the plaintiffs’ motion for summary judgment, but the appellate court reversed. The case clarified the legal standards for holding drivers responsible when they fall asleep while operating a vehicle.
Background Facts
The plaintiffs brought a lawsuit after their son died in a car accident. He had been a passenger in a vehicle driven by defendant Timothy M. Heyward. According to the evidence, Heyward fell asleep while driving. As a result, the car left the roadway and went down an embankment, causing the death of the passenger.
In support of their motion for summary judgment, the plaintiffs presented evidence showing that Heyward had admitted to falling asleep at the wheel. The defendants did not offer any evidence to dispute that admission. However, the Supreme Court denied the plaintiffs’ motion, finding that it could not determine negligence as a matter of law based solely on Heyward’s admission.
Question Before the Court
The key issue before the Appellate Division was whether falling asleep while driving, with no explanation or excuse offered, creates a presumption of negligence that entitles a plaintiff to summary judgment. The court also examined whether the defendant had presented enough evidence to create a factual dispute and avoid judgment as a matter of law.
Court’s Decision
The Appellate Division reversed the lower court’s decision. It held that when a plaintiff provides evidence that a defendant fell asleep while driving, a rebuttable presumption of negligence arises. If the defendant does not present competent evidence to explain or excuse the conduct, summary judgment in favor of the plaintiff is appropriate. Because Heyward admitted to falling asleep and offered no explanation, the court granted the plaintiffs’ motion for summary judgment on liability.
Discussion
The court reviewed prior decisions addressing whether falling asleep at the wheel constitutes negligence. It rejected earlier rulings that treated this issue as always requiring a jury determination. Specifically, the court noted that Aiello v. Garahan, a case that had held falling asleep was not negligence as a matter of law, had already been overruled by Kilburn v. Bush. In Kilburn, the Fourth Department held that falling asleep while driving raises a presumption of negligence, placing the burden on the defendant to provide a valid explanation.
The court in this case adopted the same reasoning. Driving requires continuous attention, and it is unlikely that someone would fall asleep without some warning. Therefore, when a defendant admits to falling asleep, the law presumes negligence unless the defendant can show evidence of a sudden and unforeseen loss of consciousness or some other justifying circumstance.
This presumption is rebuttable, not conclusive. It does not require an automatic finding of negligence in every case. Instead, the presumption shifts the burden to the defendant to provide an explanation. If the defendant does not meet that burden, summary judgment may be appropriate.
The court cited several cases in which similar outcomes had been reached. In Augello v. Denigris, the court affirmed summary judgment where the defendant admitted to falling asleep and offered no rebuttal. Likewise, in Herte v. Breen, summary judgment was upheld after the defendant rear-ended another vehicle and admitted to falling asleep. In Stanley v. Burnside, the court noted that falling asleep at the wheel created a presumption of negligence and granted summary judgment when no evidence was offered to rebut that presumption.
In contrast, the defendants in this case relied on outdated precedents like Vignola v. Britts, which had treated the issue as a jury question. The court clarified that those cases should no longer be followed and reaffirmed that a presumption of negligence applies when a driver falls asleep at the wheel without offering a valid excuse.