Property Owner Not Liable for Injuries Caused by Unforeseeable Third-Party Vehicle Misconduct

The plaintiff, Jarvis Coleman, attended an event hosted by Via at an entertainment venue and, upon leaving the premises, was struck by a truck driven by another patron while waiting in line to exit the parking lot. Coleman claimed that Via negligently failed to implement traffic control measures and direct vehicle flow, which he alleged proximately caused his injuries.

The appellate court rejected this argument, holding that Via’s alleged negligence was not the proximate cause of Coleman’s injuries because the intervening criminal and negligent actions of the third-party driver were unforeseeable and broke the chain of causation. The court emphasized that a defendant is generally not liable for harm caused by the extraordinary misconduct of third parties unless such conduct is reasonably foreseeable. Citing precedent, the court noted that premises owners cannot be expected to anticipate highly unusual or improbable vehicle behavior, such as a parked vehicle suddenly accelerating into pedestrians due to the actions of a passenger.

Because the chain of events leading to Coleman’s injury was extraordinary and unforeseeable, the court concluded that Via could not be held liable as a matter of law. Accordingly, the trial court’s grant of summary judgment was affirmed. 

The decision reinforces that property owners are not liable for third-party conduct that constitutes a superseding cause beyond the scope of foreseeable risk. 

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