A Rolls Royce on the Hartford - New London Turnpike Gets Connecticut's Accident Law Rolling

Car Accident Law 
From the Roaring 20's

Mahoney v. Beatman, 147 A. 762, 110 Conn. 184 (1929)

    It was July 1926, the Great Gatsby era, the height of the Roaring 20’s.  Edward Mahoney was speeding towards the Connecticut shore on the Hartford – New London Turnpike (nowadays you would take Route 2) in his brand new Rolls Royce, his chauffeur at the wheel, the speedometer marking 60 miles per hour.  Joseph Beatman was coming the other way driving his Nash (made in Wisconsin, the Nash automobile company merged with Hudson to form American Motors Corporation, whose best known car was the Rambler and which was bought out by Chrysler in 1987  — ask your grandfather).

    Proving that you do not need to be texting on a cell phone to drive distracted and cause a car accident, Joe was turned toward the back seat as he drove, presumably having a conversation with his passengers, perhaps about whether Babe Ruth would again slam 50 homers that year.

    Joe’s Nash crossed over the center of the road.  Ed’s chauffeur tried to avoid the crash by driving off the concrete highway onto the gravel shoulder.  The Nash struck the hub caps of the Rolls Royce’s left front wheel, the spare wheel on the running board, and the fender.  The Rolls Royce went diagonal for 125 feet, crossed the road, hit a tree, knocked down a 2 1/2 foot stone wall and rolled over onto its side.  The chauffeur never braked after the collision.

    Fortunately, Ed and his chauffeur were okay.  Ed’s Rolls Royce, however, was not.  To repair the damage caused by the accident would cost $5850, a stupendous auto body shop bill equal to $77,000 today.

 

    Ed hired a lawyer and sued.  Joe’s lawyer argued that if the chauffer had not been racing along at 60 mph, he would have been able to maintain control after the impact and the damage to the Rolls Royce would have been much less.

    The case was tried to a judge.  Concluding that the accident was wholly caused by Joe driving onto the wrong side of the road, but agreeing with Joe’s lawyer that the chauffeur’s unreasonable speed caused him to lose control of the car after the collision, the judge gave Ed only $200 for the accident.  A very unhappy Ed appealed to the Connecticut Supreme Court.

    In deciding the case, the Supreme Court’s ruling established a fundamental principle still used today by Connecticut’s courts to determine when a negligent driver (or his insurance company) must pay for damage caused by his carelessness.  This rule applies to all tort, negligence, and personal injury cases, not just to car accident cases.

    The Supreme Court’s decision came out on November 7, 1929, nine days after Black Tuesday, when the stock market crashed, the roaring twenties hushed up, and the Great Depression started.  Given that he had a Rolls Royce and a chauffeur to drive it, Ed undoubtedly was a member of that gilded age’s millionaire club and he probably took a beating when the market collapsed.  The Court’s decision must have given him a ray of sunshine during those dark times.  Reasoning that because the chauffeur’s speed had nothing to do with bringing about the accident, the Court ruled that Joe’s crossing the center of the road was the “proximate cause” of all of Ed’s damages and ordered the trial court to make Joe responsible for the full $5850 repair bill to the Rolls.

    The Supreme Court stated that a careless or negligent person is responsible for all natural and probable consequences of the careless or negligent act.  If the negligent person’s act is a substantial factor in producing the damages, then he or she must pay for the damage, unless an independent and unexpected force intervenes to produce the damage.

    Applying this rule to the facts of the case, the Court held that the chauffeur’s speed was not a new and independent event that caused the damage.  All of the damage arose because Joe crossed the line.  Whether the Rolls was traveling below, at or above the speed limit had nothing to do with causing the accident.  The 60 mph speed of the Rolls therefore was not a proximate cause of the damage.

 

    Whether Ed ever collected the $5850 from Joe or Joe’s insurance company for this accident is a different story.  And even if he got paid, perhaps as a result of the stock market crash he ultimately had to give up his Rolls Royce and his chauffeur.

 

    Ed’s name lives on, however, linked to the most famous ruling in Connecticut tort and personal injury law, Mahoney v. Beatman, that if you case an accident because of your negligence or carelessness, do not complain that the damages would have been less if the other driver had managed to better control her car after the crash, or had been wearing a seat belt (why not a crash helmet?), or was more physically fit, or had been driving a Hummer  — none of those things have anything to do with causing the accident itself.