McCoy v. American Suzuki Motor Corp.
Supreme Court of Washington
961 P.2d 952 (Wash. 1998)
James McCoy (plaintiff), a passing motorist, stopped to help passengers after a Suzuki Samurai swerved off the road and flipped over. As McCoy was about to leave the scene, he was struck in a hit-and-run by another vehicle. McCoy sued American Suzuki Motor Corp. (Suzuki) (defendant) under a products-liability theory, alleging the vehicle's defect was the proximate cause of his rescuer injuries. The trial court found any defect was not the proximate cause of McCoy's injuries and ruled for Suzuki, but the court of appeals reversed, holding an injured rescuer need not prove proximate cause under the rescue doctrine. Suzuki appealed.
Whether, under the rescue doctrine, the rescuer must still prove that the tortfeasor's action was the proximate cause of his injury.