Florida Court of Appeals Says Driver Can Sue Boca Raton over Malfunctioning Traffic Light
The Florida Court of Appeals in, Marion v. City of Boca Raton, recently reversed the lower court's judgment and is now allowing the plaintiff to proceed with a cause of action for negligence against the city of Boca Raton for failing to repair a traffic light that resulted in a vehicle accident. The decision, handed down last month, is good news for Boca Raton drivers.
The Facts of the Case
Elizabeth Marion was driving westbound on Glades Road when she approached the intersection of Glades Road and Renaissance Way; a major intersection in Boca Raton. The traffic control lights had malfunctioned and were operating in "safe mode." (In safe mode, the traffic lights flash yellow for drivers on Glades Road and flash red for drivers on Renaissance Way.)
Marion hit a car traveling north on Renaissance Way as she entered the intersection on Glades Road and was injured in the accident. She sued the owner and driver of the other car as well as the city of Boca Raton for negligence in failing to exercise their duty of care. (Negligence means that a party has a duty to another, the party breached that duty, and that breach caused injury to the party.)
Notably, in its decision, the court of appeals pointed out that the city had been called to that particular intersection as a result of the traffic control devices going into safe mode and flashing yellow and red lights twice within 36 hours before the accident. Each time workers responded to the problem, they simply reset the lights, but did not change the monitor responsible for putting the lights into safe mode or even determine why the problem occurred.
The Driver's Claims
Marion alleged that Boca Raton was negligent because they had a duty to maintain the traffic control device at the intersection and didn't despite the light's failure several times before her accident. And because of their failure to fix or maintain the traffic light, Marion alleges, the city caused her motor vehicle accident to occur.
The City's Defenses
In opposition, the city of Boca Raton stated that they didn't have a duty to the plaintiff or drivers to fix the traffic control device, only warn them about hazardous intersections. They allege they did so via the safe mode flashing lights.
The city further asserted that their failure to maintain the light or that the flashing lights did not cause the plaintiff's vehicle accident. Although they likely contributed to it, Boca Raton argues that poor driving was the actual cause of the crash. Even with the lights in safe mode, the city said, the accident could have been avoided if the drivers were proceeding with appropriate caution.
Case History
The defendant, city of Boca Raton filed a motion for summary judgment and asked the trial court (Fifteenth Judicial Circuit Court of Palm Beach County) to dismiss the case. The trial court agreed and granted summary judgment for Boca Raton. The court reasoned, in short, that the plaintiff, Elizabeth Marion, failed to prove that the city was negligent.
Marion appealed the ruling and asked the Florida Court of Appeals to reconsider.
The Florida Court of Appeals' Decision
The Florida Court of Appeals disagreed with the lower court and reversed their ruling. The court indicated that the city did in fact have a duty to maintain existing traffic control devices for drivers and stated that the warning alone does not discharge the city of its obligation to maintain traffic control devices. They also indicated that the city was not properly maintaining the traffic devices to operate as intended.
The court also determined that the flashing lights may have been the cause of the accident, reasoning that "the failure to have an operable traffic signal at that intersection created a zone of risk posing a threat of harm to motorists willing to brave traversing it."
Court Allows Driver to Sue City
Since the Florida Court of Appeals reversed the lower court's decision, Marion may now continue to pursue a cause of action for negligence against the city of Boca Raton for failing to properly maintain its traffic control devices.
The decision, some say, provides a clear warning to the city of Boca Raton; repair and maintain traffic control devices or risk liability for motor vehicle accidents if the lights malfunction.
