Feaster v. Tyler

CourtSuperior Court of Delaware
DecidedSeptember 3, 2024
DocketN22C-08-090 FWW
StatusPublished

This text of Feaster v. Tyler (Feaster v. Tyler) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Feaster v. Tyler, (Del. Ct. App. 2024).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

GENINE FEASTER, ) ) Plaintiff, ) ) v. ) C.A. No.: N22C-08-090 FWW ) DANIEL TYLER, and ) CW TRANSPORT, LLC, ) ) Defendants. )

Submitted: August 12, 2024 Decided: September 3, 2024

Upon Plaintiff Genine Feaster’s Motion for Summary Judgment on the Issue of Liability: DENIED

ORDER

Kenneth M. Roseman, Esquire, KENNETH ROSEMAN, P.A., 1300 N. King Street, P.O. Box 1126, Wilmington, DE 19899, Attorney for Plaintiff.

Wade A. Adams III, Esquire, LAW OFFICES OF WADE A. ADAMS III, Christiana Executive Campus, 111 Continental Drive, Suite 309, Newark, DE 19713, Attorney for Defendants.

WHARTON, J. This 3rd day of September 2024, upon consideration of Plaintiff Genine

Feaster’s (“Feaster”) Motion for Summary Judgment on the Issue of Liability,1 the

Response of Defendants Daniel Tyler (“Tyler”) and CW Transport, LLC (“CW”)

(collectively, “Defendants”),2 Feaster’s Reply,3 and the record, it appears to the

Court that:

1. An accident occurred between motor vehicles operated by Tyler and

Feaster. The front of Tyler’s vehicle allegedly struck the rear of Feaster’s vehicle

while it was stopped at a red light.4 It is admitted that Tyler was an employee of CW

and that the accident occurred on July 7, 2021.5

2. Feaster filed her complaint on August 9, 2022, alleging that Tyler: (1)

failed to maintain a proper lookout; (2) failed to maintain control over a motor

vehicle; (3) operated a motor vehicle in a careless and inattentive manner; (4)

followed a motor vehicle too closely; and (5) operated a motor vehicle at a high rate

of speed.6 Defendants answered the complaint on September 2, 2022, denying

liability and asserting various affirmative defenses.7

1 D.I. 34. 2 D.I. 38. 3 D.I. 39. 4 Pl.’s Mot. for Summ J. at ¶ 1, D.I. 34. 5 Defs.’ Ans. ¶¶ 4-5, D.I. 4. 6 Compl. at ¶ 6(a-e), D.I. 1. 7 Defs.’ Ans., D.I. 4. 2 3. Feaster moved for summary judgment on the issue of liability on July

17, 2024.8 Defendants responded on August 6, 2024.9 Feaster replied in support of

her motion on August 12, 2024.10

4. In moving for summary judgment, Feaster contends that the following

are undisputed facts: (1) Feaster’s vehicle was stopped at a red light; (2) Tyler’s

vehicle was stopped to the rear of Feaster’s vehicle; (3) while stopped to the rear of

Feaster’s vehicle, Tyler’s foot eased off of the brake pedal; and (4) when Tyler’s foot

eased off of the brake pedal, Tyler’s truck moved forward and struck the rear of

Feaster’s vehicle.11 Feaster argues that Tyler failed to maintain control of his motor

vehicle and that this failure caused his vehicle to strike Feaster’s stopped vehicle.12

Feaster writes: “[s]pecifically, by easing his foot off of the brake pedal when the

Plaintiff’s vehicle was still stopped in front of his vehicle, the Defendant could not

stop or steer his vehicle safely by objects or other vehicles on the highway.”13 Citing

Pattern Jury Instruction 6.2 and 21 Del. C. § 4176, Feaster argues that Tyler violated

his common law and statutory duty to maintain control of the vehicle.14 Ultimately,

Feaster concludes that there is no genuine issue of material fact as to her assertion

8 Pl.’s Mot. for Summ. J., D.I. 34. 9 Defs.’ Resp., D.I. 38. 10 Feaster’s Reply, D.I. 39. 11 Pl.’s Mot. for Summ. J. at 3, D.I. 34. 12 Id. 13 Id. 14 Id. 3 that Tyler’s failure to maintain control of his vehicle caused the impact with Feaster’s

vehicle.15 For that reason, she asks the Court to grant her summary judgment on the

issue of liability.

5. Defendants contend that it is premature for the Court to determine

negligence.16 Defendants state that Tyler has not been deposed.17 Further, Tyler has

not yet fully explained the facts and circumstances regarding the easing of his foot

off of the brake nor has he explained what that means in regard to the truck he was

driving.18 Defendants argue that the reasonableness of Tyler’s actions is a question

of fact for the jury to decide.19 Specifically, the jury can decide whether a reasonable

person in Tyler’s position would anticipate the set of facts that led to his foot easing

off of the brake and whether a reasonable person in a similar situation would have

expected the vehicle to move.20 Lastly, Defendants argue that the jury is entitled to

hear the facts of the accident through Tyler’s testimony and/or expert testimony to

determine if the accident was the proximate cause of any injuries alleged by

Feaster.21

15 Id. at 4. 16 Id. at ¶ 5. 17 Id. 18 Id. 19 Id. 20 Id. 21 Id. 4 6. Feaster replies that Defendants failed to demonstrate the presence of

any material facts to support a finding that Tyler was not negligent.22 Specifically,

Defendants did not submit an affidavit, nor identify any fact of record to support a

finding that Tyler was not negligent.23 Feaster states that “[a]bsent an affidavit or

the demonstration of a record fact in support of his position, the Defendant failed to

meet the shifted burden to show the presence of material issues of fact to be resolved

by the ultimate factfinder.”24

7. Superior Court Civil Rule 56(c) provides that summary judgment is

appropriate if “there is no genuine issue as to any material fact and that the moving

party is entitled to a judgment as a matter of law.”25 The moving party initially bears

the burden of demonstrating that the undisputed facts support its claims or

defenses.26 If the moving party meets its burden, the burden shifts to the non-moving

party to show that there are material issues of fact to be resolved by the ultimate

factfinder.27 When considering a motion for summary judgment, the Court's function

is to examine the record, including “the pleadings, depositions, answers to

22 Pl.’s Reply at 2, D.I. 39. 23 Id. 24 Id. 25 Super. Ct. Civ. R. 56(c); Buckley v. State Farm Mut. Auto. Ins. Co., 139 A.3d 845, 847 (Del. Super. Ct. 2015), aff'd, 140 A.3d 431 (Del. 2016) (quoting Moore v. Sizemore, 405 A.2d 679, 680 (Del. 1979)). 26 Sizemore, 405 A.2d at 681. 27 Brzoska v. Olson, 668 A.2d 1355, 1364 (Del. 1995). 5 interrogatories, and admissions on file, together with the affidavits, if any,” in the

light most favorable to the non-moving party to determine whether genuine issues

of material fact exist “but not to decide such issues.”28 Summary judgment will only

be appropriate if the Court finds there is no genuine issue of material fact. When

material facts are in dispute, or “it seems desirable to inquire more thoroughly into

the facts, to clarify the application of the law to the circumstances,” summary

judgment will not be appropriate.29 However, when the facts permit a reasonable

person to draw but one inference, the question becomes one for decision as a matter

of law.30

8. The gravamen of Feaster’s argument appears to be that there is no

genuine dispute over whether Tyler failed to maintain control of his motor vehicle;

and then, whether Tyler’s failure to maintain control of his vehicle caused it to strike

Feaster’s stopped vehicle. Feaster bases her argument on interrogatories answered

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Related

Brzoska v. Olson
668 A.2d 1355 (Supreme Court of Delaware, 1995)
Moore v. Sizemore
405 A.2d 679 (Supreme Court of Delaware, 1979)
Ebersole v. Lowengrub
180 A.2d 467 (Supreme Court of Delaware, 1962)
Wootten v. Kiger
226 A.2d 238 (Supreme Court of Delaware, 1967)
Merrill v. Crothall-American, Inc.
606 A.2d 96 (Supreme Court of Delaware, 1992)
Buckley v. State Farm Mutual Automobile Insurance
139 A.3d 845 (Superior Court of Delaware, 2015)
State Farm Mutual Automobile Insurance Co. v. Buckley
140 A.3d 431 (Supreme Court of Delaware, 2016)

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Feaster v. Tyler, Counsel Stack Legal Research, https://law.counselstack.com/opinion/feaster-v-tyler-delsuperct-2024.