Background
Three people died after Morgan Ryder drove through a stop sign at a rural Woodford County intersection and collided with an ambulance traveling on Illinois Route 116. Seth Unruh and Jared Seggerman were passengers in Ryder’s vehicle. Ryder did not come to a complete stop, although the stop sign was clearly visible.
The estates alleged that corn grown on the northeast corner of the intersection violated a county visibility ordinance and obstructed sight lines. They sued the landowners and farmers for negligence and wrongful death. It was undisputed, however, that a driver who stopped where required could see traffic on Route 116, including the ambulance.
The Court’s Holding
The appellate court affirmed summary judgment for all defendants. Even assuming the corn was grown in violation of the county ordinance, the plaintiffs could not establish proximate cause as a matter of law.
Under the undisputed facts, Ryder’s failure to stop was an intervening act that severed any causal connection between the alleged ordinance violation and the crash. The court held that a reasonable person in defendants’ position would not foresee a driver’s failure to obey the visible stop sign as a natural and probable result of corn that neither blocked the sign nor blocked the view of Route 116 for a stopped driver.
Key Takeaways
- An ordinance violation does not establish negligence liability without proof of proximate cause.
- Foreseeability of an intervening act alone is insufficient; it must be a natural and probable result of the alleged negligence.
- A driver’s failure to obey a visible stop sign can be an efficient intervening cause when the alleged visibility obstruction did not prevent a stopped driver from seeing approaching traffic.
Why It Matters
The decision limits liability for adjacent landowners and farmers in sight-line cases where an alleged obstruction did not conceal the traffic control device or prevent a lawfully stopped driver from seeing cross traffic. The court treated the cornfield as a condition of the crash, rather than its legal cause.