SC Supreme Court Interprets State’s Liability for Motorcycle Accident

Understanding the various causes of motor vehicle accidents is a crucial aspect of personal injury litigation. From accidents caused by drunk drivers to wrecks resulting from automotive defects, an auto accident lawyer must explore all potential sources of liability to help a client pursue full compensation for catastrophic injuries and other losses.

In a recent decision, Boiter v. South Carolina DOT, the South Carolina Supreme Court considered the amount of damages for which state authorities should be held accountable for injuries suffered in a motorcycle accident that resulted from inoperative traffic lights. Under the South Carolina Tort Claims Act, government liability for accidents is strictly limited in light of the general immunity from lawsuits granted to the state, its political subdivisions, and its employees while acting within the scope of their official duties.

In the present case, a husband and wife suffered serious injuries when the motorcycle they were riding was struck by a car at an intersection near Inman. The red signal light facing the road traveled by the automobile had burned out earlier in the day, and the driver failed to stop as intended by the traffic signal. The couple suffered serious injuries, and claimed medical expenses and lost income in excess of $1 million.

Challenging the Damages Awarded for Failure to Prevent an Accident

The injury victims settled with the driver's insurance company for $50,000, the full extent of the policy limits. They also filed negligence claims against the Department of Transportation (DOT) and Department of Public Safety (DPS) based on the agencies' failure to prevent the motorcycle accident. The plaintiffs alleged that the DOT failed to implement a policy that replaced traffic light bulbs before they burned out, and that the DPS had received notice of the outage more than an hour before the accident and should have provided a trooper to direct traffic.

The state did not dispute the negligence claim, and a trial jury awarded damages of $1.875 million to both the husband and wife. The state filed a post-trial motion for reduction of the damages pursuant to the provisions of the Tort Claims Act, and the court reduced the damages to $300,000 for each of the injured parties. The plaintiffs responded with a motion challenging the constitutionality of the damages cap and asserting that each state agency's negligence should be counted as a separate occurrence and thus a larger damages award was authorized. The trial court rejected these arguments.

On appeal, the South Carolina Supreme Court rejected the plaintiffs' complex argument that different damages caps under the Tort Claims Act violated their rights under the Equal Protection Cause of the 14 th Amendment to the U.S. Constitution. However, the court was persuaded that the state's liability in this case was based upon "two separate and distinct acts of negligence involving two separate and distinct entities together with separate verdicts against each of them." Accordingly, the court held that the plaintiffs were entitled to a doubling of damages as a matter of law, clarifying an important legal principle for future accident victims.

Exploring Diverse Sources of Personal Injury Compensation

Injury victims and family survivors of fatal accident victims may only think of the most obvious potentially liable parties after a motor vehicle accident. One of the most important roles of a South Carolina car accident lawyer is to identify every potential source of liability and craft smart legal strategies to pursue full compensation.

For example, after a trucking accident caused by a driver's admitted inattention that leads to a catastrophic rear-end pile-up, evidence of an overloaded trailer or inadequate brakes can also play an important role in litigation. Untried theories of liability, such as the separate negligence argument that persuaded the majority in the Boiter case, are another hallmark of experienced personal injury and wrongful death representation.

Just as important, an attorney's ability to demonstrate the full extent of a client's damages can make a considerable difference in the outcome. This includes expert assessment of the likelihood of medical recovery, as well as identification of unique aspects of the harm suffered by an injured party. In every case, a law firm's ability to articulate legal arguments on appeal has strong implications for the ultimate success of a personal injury claim.