## Facts

- During a sudden rainstorm on Interstate 80 in Pennsylvania, a driver (Klopp) abruptly stopped, prompting a following tractor–trailer (Jackson, for Sharkey Transportation) to jackknife to avoid a collision and block both westbound lanes.
- Minutes later, a power line owned by Pennsylvania Power & Light Company fell across the highway for unknown reasons, creating an additional obstruction.
- Roughly one-half mile behind the initial jackknife, a second tractor–trailer (Watley) rear-ended a car, jackknifed, and came to rest near a guardrail amid slowing and stopped traffic.
- A Pennsylvania State Police trooper responded and attempted to reroute traffic around the blocked interstate.
- About two hours after the first incident, a delivery truck driver (Questore) entered the affected area and rear-ended a vehicle driven by Franz (with Valerie Taylor as a passenger) and also struck a vehicle driven by Lindow, causing serious injuries to Taylor and the Lindows.
- The Taylors and the Lindows sued multiple private parties tied to the earlier events and the later collision, and they also asserted claims against the Pennsylvania State Police.
- Jackson, Sharkey, and Shippers (connected to Jackson’s trailer) asserted claims against the Pennsylvania State Police based on traffic control and scene management.
- The trial court granted summary judgment for the private defendants against the plaintiffs, ruling earlier conduct was not a substantial factor in the later injuries and that Questore’s conduct was a superseding cause as a matter of law.
- The trial court also granted summary judgment for the Pennsylvania State Police on sovereign immunity grounds.
- The plaintiffs and certain defendants appealed; the appeals were consolidated.

## Issues

1. Whether the trial court erred in holding, as a matter of law, that earlier conduct and resulting highway conditions were not a substantial factor in causing injuries from a later collision occurring about two hours afterward.
2. Whether the trial court erred in holding, as a matter of law, that Questore’s conduct was a superseding cause relieving earlier actors of liability.
3. Whether sovereign immunity barred claims against the Pennsylvania State Police, including whether statutory exceptions for dangerous conditions of Commonwealth realty or negligent vehicle operation applied.

## Decision

- Reversed the summary judgments for the private defendants and remanded for further proceedings.
- Held that, on this record, reasonable factfinders could differ on whether the earlier events and continuing highway hazards were a substantial factor in the injuries, making summary judgment improper.
- Held that whether Questore’s conduct was a superseding cause turned on foreseeability and disputed facts and was generally for the jury.
- Affirmed summary judgment for the Pennsylvania State Police, holding sovereign immunity applied and no statutory exception was shown.

## Legal Principles

- Under Pennsylvania tort law, proximate cause is evaluated using the “substantial factor” test, and it is ordinarily a jury question when reasonable minds may differ.
- A lapse of time between an earlier negligent act and a later injury does not, by itself, sever causation as a matter of law where the risk and hazardous conditions may remain ongoing.
- Superseding cause depends on foreseeability and is typically for the jury when material facts about the sequence of events, warnings, visibility, and traffic conditions are disputed.
- Claims against the Commonwealth are barred by sovereign immunity unless a statutory exception applies; scene-management allegations do not fit the real estate exception absent a dangerous condition of Commonwealth realty, and do not fit the vehicle exception absent negligent operation of a Commonwealth vehicle.

## Conclusion

The court held that causation questions in a multi-incident highway chain—whether earlier conduct remained a substantial factor and whether later negligence was superseding—should generally go to the jury on a disputed record, but it also held that sovereign immunity shielded the Pennsylvania State Police because the asserted statutory exceptions were not satisfied.


Taylor v. Jackson, 643 A.2d 771 (Pa. Commw. Ct. 1994)