The Indiana Court of Appeals recently upheld the grant of summary judgment in favor of the estate of a vehicle driver who suffered a heart attack and became unconscious while driving, which resulted in his vehicle speeding up, going off the roadway, and crashing into a nearby house. The vehicle driver died and his passenger, who brought suit against his estate, suffered severe injuries.
In Indiana, a plaintiff must establish three elements to prove negligence on behalf of a defendant: (1) a duty owed to the plaintiff by the defendant; (2) a breach of that duty by failing to comply with the applicable standard of care; and (3) a compensable injury proximately caused by the breach of that duty. Under Indiana law, individuals must conform their conduct to that of a reasonable person under like circumstances. Summary judgment is appropriate when the defendant negates at least one of the elements of the plaintiff’s claim. While the element of breach is usually a question for the jury, where the relevant facts are undisputed and lead only to a single inference or conclusion, the court may determine as a matter of law whether the defendant breached a duty.
The defendant estate in this case claimed it was entitled to summary judgment on the element of breach because the vehicle driver could not be found to have acted unreasonably in causing the collision when he suffered a heart attack and was rendered unconscious. The plaintiff passenger argued that the defendant driver was negligent for driving in the first place given his medical condition. While the vehicle driver had recently suffered a prior heart attack and undergone treatment related to his heart condition, at the time of the collision, he had been cleared to drive by his medical providers. Based upon this evidence, the Court found that the passenger plaintiff failed to create a genuine issue of material fact as to whether the defendant driver’s sudden physical incapacity was reasonably foreseeable, so as to hold him negligent for driving in the first place.