Anyone who drives in Atlanta knows that Interstate 75 is a busy highway and that accidents along this stretch of road are far from unusual. Among the sorts of motor vehicle accidents that are particularly common are those involving tractor-trailers traveling to or through the metropolitan area. Given their size, tractor-trailers pose unique risks to other motorists and require particular care in their operation. In fact, in a recent case, Dogan v. Buff, the Georgia Court of Appeals addressed whether it was appropriate for a trial court to grant summary judgment in favor of a tractor-trailer driver and his employer following a multi-vehicle accident on I-75.
The accident at issue in this case occurred on February 18, 2009. One driver was heading north on I-75 near Roswell Road in a van owned by his employer, Royalty Transportation. The driver had just taken a patient at Emory Hospital and was heading back to retrieve a different patient. It had just rained, and the road was wet. At the same time, a second driver was hauling various dialysis supplies to Chattanooga in a tractor-trailer owned by his employer, Rockwell Transportation. The trailer was loaded with 80,000 pounds of goods, and Rockwell’s trucking manual required that its drivers maintain one truck length between the tractor-trailer and the vehicle in front of it for every 10 mph the trailer is traveling. The tractor-trailer was following the van operated by the first driver when two other vehicles traveling along the road collided as a result of an errant merging of lanes. The driver of the van changed lanes and slammed the brakes to avoid hitting the cars that collided, and the driver of the tractor-trailer, which was only traveling behind the van by three passenger car lengths, did the same but rear-ended the van. Both vehicles sustained moderate damage, and the driver of the van was taken from the scene to receive medical care. Following the accident, the first driver sued the tractor-trailer driver and Rockwell, alleging that his injuries were a result of the tractor-trailer driver’s negligent and reckless operation of the vehicle. Following the conclusion of discovery, the defendants moved for summary judgment, and the trial court granted the motion.