Dooley v. United States

CourtCourt of Appeals for the Second Circuit
DecidedOctober 5, 2023
Docket22-995
StatusPublished

This text of Dooley v. United States (Dooley v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dooley v. United States, (2d Cir. 2023).

Opinion

22-995 Dooley v. United States IN THE

United States Court of Appeals For the Second Circuit ________

AUGUST TERM, 2022

ARGUED: APRIL 20, 2023 DECIDED: OCTOBER 5, 2023

No. 22-995

KEVIN DOOLEY, Plaintiff-Appellant,

v.

UNITED STATES OF AMERICA, Defendant-Appellee. ________

Appeal from the United States District Court for Southern District of New York 1:18-cv-7136 – Gorenstein, Magistrate Judge. ________

Before: CALABRESI, PARK, and LEE, Circuit Judges.

________ 22-995 Dooley v. United States

Plaintiff-appellant Kevin Dooley (“Dooley”) appeals from a judgment of the United States District Court for the Southern District of New York (Gorenstein, M.J.). While riding his bicycle, Dooley collided with the open door of a car owned by the United States and operated by a United States employee. Dooley brought a claim for negligence against the United States, pursuant to the Federal Tort Claims Act. The district court found the United States liable, but concluded Dooley also acted negligently and was therefore partially liable. On appeal, Dooley contends, inter alia, that the district court erred in finding his negligence caused the accident. We agree. We therefore VACATE and REMAND.

Judge Park dissents in a separate opinion.

MICHAEL AVILES, Michael J. Aviles & Associates, LLC, New York, NY, in

support of Plaintiff-Appellant.

JENNIFER JUDE, Assistant United States Attorney (Christopher Connelly,

Assistant United States Attorney, on the brief), for Damien Williams,

United States Attorney for the Southern District of New York, New

York, NY.

CALABRESI, Circuit Judge:

This case arises from a dooring accident: a delivery man was riding his

bicycle down Burke Avenue in the Bronx, when he hit the interior of the open door

2 22-995 Dooley v. United States

of a U.S. government car parked by the curb. Because the car was owned by the

federal government and was driven by a federal employee in the course of his

employment, the plaintiff brought a claim for negligence against the United States

pursuant to the Federal Tort Claims Act (“FTCA”). The district court found that

the government employee acted negligently by opening the car door without

checking for incoming traffic; it also concluded that the plaintiff’s conduct was

comparatively negligent and assigned 40% liability to the plaintiff. Under New

York law, which governs this case, a court will find a plaintiff comparatively

negligent, and reduce a damages award accordingly, only if a plaintiff’s

negligence was a proximate cause of the accident. 1 A defendant, furthermore,

bears the burden of establishing both that a plaintiff’s conduct was negligent and

that a plaintiff’s negligence was a proximate cause of the injury.

1 Causation is typically described as having two components, causation in fact—a showing that the accident would not have occurred but for the plaintiff’s wrong—and proximity—a showing that the plaintiff’s wrong was sufficiently close in and significant in time, space, and foreseeability as to justify the plaintiff’s responsibility. See W. Page Keeton, et al., Prosser & Keeton on Law of Torts §§ 41-42, at 263-65, 272–73 (5th ed. 1984). At times, New York courts have, perhaps confusingly, united these two components and spoken of the requirement as one of proximate cause, even where often, as in this case, the issue is primarily one of cause in fact. Compare Akins v. Glens Falls City Sch. Dist., 424 N.E.2d 531, 535 (N.Y. 1981) (referring to causation in general terms) with Solomon by Solomon v. City of New York, 489 N.E.2d 1294, 1294 (N.Y. 1985) (referring only to proximate causation).

3 22-995 Dooley v. United States

The district court’s finding that the plaintiff here acted negligently may, in

several respects, be viewed as dubious on this record. But, and determinatively,

the district court failed to make the findings necessary to any holding that the

plaintiff’s negligent conduct sufficiently caused the collision so as to make the

plaintiff 40% responsible for the damages. Accordingly, and without reaching any

issue of plaintiff negligence, we VACATE and REMAND for reconsideration

consistent with this opinion.

BACKGROUND

On May 18, 2017, Sergeant Luis Disla (“Disla”), a recruiter for the United

States Marines, parked his assigned government vehicle on Burke Avenue in the

Bronx, near a high school he was scheduled to visit. Around the same time, Kevin

Dooley (“Dooley”), a delivery man employed by a local restaurant, was riding a

motorized bicycle down Burke Avenue. Dooley was riding his bike in the space

between the parked vehicles and the edge line of the westbound traffic lane of

Burke Avenue. 2 According to Dooley, he was driving straight, “in the middle” of

2In his testimony, Dooley characterized this space as a bike lane. Photographs taken at the time of the accident, as well as Disla’s testimony, indicate the space was not then clearly marked as a bike lane and only became a marked bike lane after the accident.

4 22-995 Dooley v. United States

the space between parked vehicles and the moving-traffic lane and was traveling

at around 15 miles per hour. App’x. 84. The weather conditions were clear, and

the posted speed limit was 25 miles per hour. Dooley recalled that traffic on the

main lane that day was light.

As Dooley approached, Disla opened the car door. Disla testified that he

did not recall looking in his mirror to check for any oncoming traffic before

opening his door. 3 Dooley averred that he saw Disla’s parked car from a distance,

but that he did not see an open door. Dooley hit the interior of the car’s open door.

Dooley stated that the right-hand side of his bicycle and the open door made

contact. 4

After hitting the car door, Dooley fell to the ground. Seeing Dooley injured,

Disla stepped out of his car and assisted Dooley. Disla testified that Dooley spoke

with slurred speech and angrily cursed at him. When emergency medical services

responded to the scene, Dooley argued with them. Dooley stated that immediately

3 In deposition statements, at one point, Disla stated that he had looked into his side mirror to ensure that there was no bicycle traffic, but he later withdrew this statement as a recollection of habit and practice rather than of his specific actions on the day of the collision. 4 The district court dismissed an alternative theory, presented by the defendant, that Disla had only unlatched and not fully opened the car door at the time of the collision.

5 22-995 Dooley v. United States

after the accident, he felt pain in his right knuckles and left leg. He sought medical

assistance later that night and again eight days later. Dooley sustained injuries to

his left knee and ankle, and he underwent knee surgery and other medical

procedures to treat his injuries.

Dooley filed a complaint against the United States, pursuant to the FTCA. 5

Dooley claimed that Disla acted negligently when he “suddenly” opened the car

door without exercising appropriate caution, and that, because the accident took

place as Disla was performing functions within the scope of his employment, the

United States was liable.

Prior to trial, Dooley and his domestic partner, Sherman Peterson

(“Peterson”), were deposed. Dooley stated that he smokes marijuana daily, but

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