Vitro America v. Ngo: Florida Court Orders New Trial in Crash Case

The case of Vitro America, Inc. v. Ngo involved a motor vehicle collision in which Michael Ngo sustained serious injuries after crashing into a truck operated by Vitro America, Inc. The trial court entered a directed verdict finding Vitro's driver negligent and responsible for the accident. However, the Florida First District Court of Appeal reversed the decision, ruling that the issue of proximate cause should have been decided by a jury. The appellate court remanded the case for a new trial.

Background and Legal Issues

On October 10, 2008, Michael Ngo was driving on Highway 98 when he collided with an eighteen-wheeler operated by a Vitro America driver. The truck driver had been executing a backing maneuver to deliver goods to a business, positioning the truck at a sharp angle that partially blocked Ngo’s lane. While the truck had hazard lights and reflective tape, Ngo claimed he did not see it in time to avoid the collision. As a result of the crash, Ngo suffered extensive injuries, particularly to his right leg, ankle, and heel.

Ngo filed a lawsuit against Vitro America, alleging negligence. At trial:

• Ngo’s expert testified that the truck's reflective tape was ineffective at certain angles and that Ngo likely did not recognize the truck as an obstacle in time to react.
• Vitro’s expert countered that Ngo should have seen the truck’s flashing lights and avoided the collision.
• The trial court ruled in favor of Ngo on the issue of proximate cause, directing a partial verdict and leaving the jury only to determine comparative fault.
• The jury found Vitro 99% at fault and Ngo 1% at fault, awarding Ngo over $8.2 million in damages.

Vitro appealed, arguing that the trial court improperly removed the issue of proximate cause from jury consideration.

Court’s Analysis and Findings

The Florida First District Court of Appeal held that:

• The trial court erred by directing a verdict on proximate cause. Given conflicting expert testimony on whether Ngo could have avoided the accident, the jury should have determined whether Vitro's negligence was the legal cause of the crash.
• The jury’s role is critical in negligence cases, and motions for directed verdicts should be granted only when reasonable minds could not differ on the facts.
• By deciding proximate cause as a matter of law, the trial court deprived Vitro of a key defense—namely, that Ngo’s own inattention was the sole cause of the accident.
• Because the jury was still allowed to assess comparative fault, the trial court’s ruling created an inconsistency, where Vitro’s driver was deemed a legal cause of the accident, yet the jury could still assign partial fault to Ngo.

Based on these findings, the appellate court reversed the judgment and remanded the case for a new trial.

Conclusion and Ruling

The Florida First District Court of Appeal ruled that the trial court improperly directed a verdict on proximate cause, which should have been decided by the jury. The case was remanded for a new trial on both liability and damages, allowing a jury to fully assess causation and fault.

Legal Guidance for Motor Vehicle Collision Cases

Understanding liability and causation in motor vehicle accidents can be complex. Our team at Whitcomb, Selinsky, PC assists clients in navigating legal challenges related to personal injury claims and motor vehicle collisions.