Is a ridesharing company liable for the death of a passenger after the ride has ended? Therein lies the question in a matter currently pending before Florida’s Fourth District Court of Appeals. It’s a case that tests the limits of the long-standing, sometimes vexing legal doctrine of proximate causation.In this post, we walk you through this doctrine and how it applies in the case of a teenager whose late-night trip to her boyfriend’s house ended in tragedy.
In the early morning hours of July 9, 2017, 13-year old Karenine Saint Louis snuck out of her home in a gated Florida community and climbed into a car she had called on the ride-hailing app, Lyft. The driver, who did not speak English and didn’t know that Lyft’s rules prohibited providing rides to minors, dropped her off at her 17-year old boyfriend’s house. Hours later, Karenine died when the pickup her boyfriend was driving her home in crashed into trees on a slippery road. The boyfriend, who was not a licensed driver, survived the crash with only minor injuries.
Karenine’s parents filed a wrongful death suit in a Florida civil court against Lyft and its driver. Their claim rested on the argument that had Lyft not transported Karenine to her boyfriend’s house that night, she would not have died in a car accident returning home. In legal terminology, the lawsuit contended that Lyft and its driver’s actions constituted the “proximate cause” of Karenine’s tragic death.Proximate causation is a doctrine that has confounded generations of lawyers. Every first-year law student learns the story of Mrs. Palsgraf, who in 1924 was injured while standing on a train platform. The circumstances of Mrs. Palsgraf’s injuries are the stuff of legal legends: two men were running to catch a train on the same platform; one of them, while being helped aboard by a railroad employee, dropped a package he was carrying; the package exploded; the concussive force of the explosion tipped over a heavy scale onto Mrs. Palsgraf, injuring her.Mrs. Palsgraf sued the railroad, claiming the railroad employee had been negligent in assisting the man whose package had exploded. But, in a now-famous opinion, the appellate judge Benjamin Cardozo wrote that Mrs. Palsgraf could not recover damages because it was not reasonably foreseeable that the railroad employee’s actions would cause the scales to tip over, and hence, those actions were not the “proximate cause” of her injuries.Courts nationwide have adopted some version of Cardozo’s well-known formulation of foreseeable harm and proximate causation. Over time, the doctrine has guided judges and lawyers through some truly bizarre and convoluted fact patterns. For example, in 1949, the Mississippi Supreme Court considered whether an employer should be held liable for its employee’s death in an explosion triggered when a gasoline-soaked rat caught fire on a pilot light and ignited a gas tank. Another court considered whether the owner of a barge that broke loose on a river and collided with a bridge piling, causing the bridge to collapse that led to a massive ice dam on the river, should be liable for the damages suffered by businesses that could not transport their goods on the river as a result of the ice dam.
The tragic death of Karenine Saint Louis adds another link to the long chain of proximate causation cases. Lyft moved to dismiss the wrongful death claim by Karenine’s parents, arguing that its actions could not have been the proximate cause of her death. In other words, Lyft argued that while it may well have been a violation of company policies (not to mention of basic community norms) for its driver to take a pajama-clad 13-year old to her boyfriend’s house that night, the driver could not have reasonably foreseen her death hours later.In January 2018, the trial court judge presiding over the case agreed with Lyft. In an opinion dismissing the claims against Lyft and the driver “with prejudice” (meaning they couldn’t be amended or re-filed), circuit court Judge Donald Hafele wrote that “it is not reasonably foreseeable that Saint Louis would, four hours after being dropped off by a Lyft driver, enter a car with an unlicensed driver who would then be involved in an automobile accident in which Saint Louis died.” In other words, “[w]hile the accident may not have happened but for Saint Louis being dropped off at [her boyfriend’s] home, it was not a natural and foreseeable result of the Lyft ride.”Karenine’s parents appealed Judge Hafele’s ruling. The case has just begun to move through the appeals court.
It is not difficult to imagine a different result. If Karenine had been riding in a Lyft car when she died, the case against Lyft would likely be stronger, even if the Lyft driver’s driving was not to blame for the crash. So, too, might the case against Lyft have survived if Karenine had been injured immediately upon exiting the Lyft driver’s car, instead of hours later.The doctrine of proximate causation also invites us to ponder more difficult cases. Suppose a young person climbs into a Lyft driver’s car wearing a bathing suit and later drowns in a swimming pool at the destination. Would the passenger’s death in such a case be treated as reasonably foreseeable? Would that case against Lyft be stronger if the young person was obviously intoxicated during the ride? These and other questions will tragically, though inevitably, continue to confront the ride-hailing industry as it grows.
If you or a loved one has been injured in an accident related to a ride-hailing company—whether in Ft. Lauderdale, Miami Beach, South Beach, Aventura, Hollywood, or anywhere in south Floida—retaining a lawyer familiar with the ins and outs of reasonable foreseeability and proximate causation can help you protect your rights and recover damages. At Uber Car Accident Law, we stay up to date on the ever-evolving laws surrounding ride-hailing companies like Lyft and Uber. To learn more, contact us today at (305) 964-8806.