Latzel v. Bartek

Thomas Latzel was a passenger in the vehicle of Daniel Vanekelenburg, who was driving, when the vehicle collided with another vehicle driven by Patrick Gaughen. The collision occurred at an unmarked intersection of two county roads. Brothers Ronald Bartek and Doug Bartek owned the land to the southwest corner of the intersection. Before Thomas died from his injuries, his wife filed a negligence action against the drivers involved in the collision and the Barteks, alleging that the Barteks were negligent by planting corn too close to the roadside and by allowing the corn to obstruct the view of the intersection. The district court granted summary judgment in favor of the Barteks, concluding that the negligence of the drivers constituted an intervening cause as a matter of law. The Supreme Court affirmed, holding that the actions of the drivers constituted an efficient intervening cause of the collision, which severed the causal connection between the conduct of the Barteks and the injuries received by Thomas.View "Latzel v. Bartek" on Justia Law