Abbott v. Mega Trucking, LLC

District Court, M.D. Alabama·Decided March 14, 2023·No. 2:20-cv-00776·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

TOURI EUGENE ABBOTT and ) PHILLIP’S AUTO RECYCLING & ) SALVAGE, INC., ) ) Plaintiffs, ) ) v. ) CASE NO. 2:20-CV-776-WKW ) [WO] MEGA TRUCKING, LLC, MUL- ) TY- VIBES, INC., and PATRICE ) LUMUMBA MORGAN, ) ) Defendants. )

ORDER ON PRETRIAL HEARING

A pretrial hearing was held in this case on March 13, 2023, wherein the following actions were taken: 1. PARTIES AND TRIAL COUNSEL:

Adam E. Parker and Reginald D. McDaniel on behalf Plaintiffs, Touri Abbott and Phillips Recycling & Salvage, Inc. Jonathan K. Corley on behalf of Mega Trucking, LLC; and Blake L. Oliver on behalf of Patrice Lumumba Morgan and Mul-Ty Vibes, Inc. 2. JURISDICTION AND VENUE:

The court has subject matter jurisdiction pursuant to 28 U.S.C. § 1332 because complete diversity exists between Plaintiffs and Defendants, and the amount in controversy exceeds $75,000.00, exclusive of interest and costs. Venue is proper because the motor vehicle accident giving rise to this action

occurred in Pike County, Alabama, which is located in the Northern Division of the Middle District of Alabama. 3. PLEADINGS: The following pleadings and amendments were allowed:

Plaintiffs’ Second Amended Complaint (Doc. # 33); Mega Trucking, LLC’s Answer to Second Amended Complaint (Doc. # 35); Patrice Lumumba Morgan and Mul-Ty Vibes, Inc.’s Answer to Second

Amended Complaint (Doc. # 36) 4. CONTENTIONS OF THE PARTIES: (a) Plaintiffs (a) The injuries Mr. Abbott received on August 24, 2020, were devastating and adversely altered his life forever. Touri Abbott’s life altering and permanent

injuries were directly caused by this collision as a result of the negligence and wantonness committed by Mega Trucking, LLC, Mul-ty Vibes and commercial truck driver defendant, Patrice L. Morgan, jointly and severally. Mr. Abbott’s

medically documented injuries include loss of full L-spine extension and loss of full spine flexion, L-Spine spine tenderness, intervertebral disc space narrowing L4-L5, and intervertebral disc space narrowing L5-S1, soft tissue exam shows swelling of

paralumbar soft tissues, T-Spine: decreased joint space, T8-T9 left paracentral disc protrusion, T9-T10 left foraminal stenosis, L5-S1, and left paracentral disc protrusion measures 2.2 cm. Medical records also document modest deflection

proximal left S1 nerve root, underlying bilateral disc bulge and bilateral foraminal stenoses with, mild facet hypertrophy, L4-5 and L5-S1 disc protrusions, compressing the L5 and S1 nerve roots respectively. Mr. Abbott underwent back surgery on August 16, 2022, by Dr. Mark Kelly

to repair the large, herniated disc. While initial reports reported some improvement, the road to maximum recovery is still unknown. His injuries are permanent, and he lives in persistent pain.

Mr. Abbott also had documented reports of pertinent positives for bowel incontinence and erectile disfunction, the former complained of immediately after the collision. Mr. Abbott’s medical damages and permanent disability have been testified

to by Dr. Leo Chen and Dr. Mark Kelley. The injuries rendered Mr. Abbott unable to work since the collision on August 24, 2020. Philips Recycling and Salvage: Property Damage for Phillip’s Recycling & Salvage, Inc. property damage and a tow bill for the following estimated/actual

amounts: 2012 Peterbilt 389 semi-truck $60,000.00 1990 Trailer $20,000.00 Tow bill $43,700.00

Plaintiffs submit that liability is clear with regard to both negligence and wantonness by Mega Trucking, Mul-Ty Vibes and Patrice Morgan. Morgan testified that he thought he had enough time to make the illegal left turn in the face of oncoming highway travel. Morgan guessed wrong, and his actions in misjudging the radius of the turn added to the negligent and wanton operation of his tractor trailer. In Alabama, negligence, in the operation of a vehicle, may occur upon a public

highway without regard to, or without any violation of, any rule of the road. "Negligence" is the failure to do what a reasonably prudent person would have done under the same or similar circumstances, or the doing of something which a reasonably prudent person would not have done under the same or similar

circumstances. See Shackleford v. Brumley, 437 So. 2d 1044 (Ala. Civ. App. 1983). A reasonably prudent, properly trained commercial truck driver would not have failed to yield the right of way into oncoming highway traffic with the oncoming

traffic clearly in view. In a recent Alabama Supreme Court case, T&J White, LLC v. Williams, No. SC-2022-0480, 2022 WL 16847601, at *5 (Ala. Nov. 10, 2022), the court affirmed

a verdict against defendants for $500,000 compensatory damages for negligence, $250,000 compensatory damages for wantonness, and $750,000 punitive damages for wantonness, arising from a rear-end collision. Evidence showed the plaintiff’s

car was decelerating while approaching a red or yellow light; the defendant driver Morse, behind the plaintiff, saw the traffic light and saw plaintiff’s car; Morse accelerated over the speed limit in an attempt to make it through the light and rear- ended plaintiff’s car; Morse was on his cell phone at the time of the collision.

The defendants, citing Ex parte Essary, 992 So. 2d 5 (Ala. 2007) (driver ran a stop sign attempting to squeeze between two oncoming cars that had the right of way) and Phillips v. United Servs. Auto. Ass’n, 988 So. 2d 464 (Ala. 2008) (where a

driver took her eyes off the road before veering into oncoming traffic) argued that they were entitled to judgment as a matter of law (JML) on the wantonness claim. The court said, “However, Phillips and Essary involved merely inadvertence or ill- advised attempts to dodge other vehicles; here, substantial evidence showed Morse

accelerated toward the plaintiff’s vehicle, raising the question of whether Morse acted consciously and intentionally. The trial court properly denied JML as to wantonness. Here, Morgan testified and the video evidence proves Morgan saw Abbott’s tractor-trailer in clear view before he decided to “push” the accelerator in an attempt

to clear Hwy 231 when Morgan failed to yield the right of way. These actions by Morgan were done consciously and intentionally, thereby constituting wantonness. Mega Trucking is responsible for any judgment against Patrice Morgan, and

Mul-Ty under 49 C.F.R. § 390.5 of the Federal Motor Carrier Safety Regulations (FMCSR). Mr. Morgan (and his LLC—Mul-Ty-Vibes) acted as an agent of Mega Trucking. He is an “employee” as defined by 49 C.F.R. § 390.5: An employee is “any individual, other than an employer, who is employed by an employer and who

in the course of his or her employment directly affects commercial motor vehicle safety. Such term includes a driver of a commercial motor vehicle (including an independent contractor while in the course of operating a commercial motor

vehicle), a mechanic, and a freight handler.” (b) Defendant Mega Trucking, LLC Mega Trucking, LLC (“Mega”) contends that it maintained an owner-operator relationship with Mul-Ty Vibes, Inc. (“Mul-Ty”), who owned the 2007 Freightliner

truck involved in the collision.

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Related

Shackleford v. Brumley
437 So. 2d 1044 (Court of Civil Appeals of Alabama, 1983)
Phillips Ex Rel. Phillips v. United Services Auto. Ass'n
988 So. 2d 464 (Supreme Court of Alabama, 2008)
Ex Parte Essary
992 So. 2d 5 (Supreme Court of Alabama, 2007)