Sic v. Nunan
Connecticut drivers owe no duty to oncoming motorists to keep their wheels straight while waiting to turn in anticipation of a potential rear-end collision. Michael Nunan lawfully stopped his vehicle in the eastbound travel lane of Route 66 intending to make a left turn and waiting for a break in oncoming traffic. A vehicle operated by Jessica Thoma struck Nunan's vehicle from behind and propelled him into the travel lane of oncoming traffic. Nunan's vehicle collided with the vehicle operated by Marie Sic. Sic suffered serious, permanent injuries. She filed this negligence action alleging, inter alia, that Nunan was negligent in stopping with his wheels turned to the left, such that if he was struck from behind his vehicle would move into the travel lane of oncoming traffic, rather than straight ahead. The trial court granted the defendant's motion for summary judgment finding that the defendant was under no duty to defend the plaintiff against the potential that his vehicle would be struck from behind by having his wheels positioned in a particular direction. The plaintiff appealed. The Appellate Court, in a divided opinion, reversed the judgment, concluding that because drivers are always under a duty to exercise reasonable care, the question of whether the defendant breached his duty of care to the plaintiff was a question of fact for the jury. The defendant appealed claiming that the Appellate Court improperly framed the dispositive question. The Supreme Court reversed the judgment. The Appellate Court improperly failed to assess the specific question of whether the defendant owed the plaintiff a duty to anticipate and guard against the tortious and unlawful conduct of another driver. The trial court properly determined that Connecticut drivers do not owe oncoming motorists a duty to keep their wheels straight when waiting to turn in anticipation of a potential rear-end collision. The Supreme Court noted its 1933 decision in Gross v. Boston, Worcester & New York Street Railway Company, that "a driver is entitled to assume that other users of the highway will obey the law, including lawful traffic regulations and observe reasonable care, until he knows or in the exercise of reasonable care should have known, that the assumption has become unwarranted."