Williams v. Steves Industries, Inc.

Renee Williams (plaintiff) ran out of gas about five miles from home, on a route she knew included busy interstate, with her two children in the back seat. Her car stalled across four lanes in a spot hidden by shadows, and an eight-ton truck owned by Steves Industries (defendant) struck it from behind. Williams was injured and both children died. A jury found Williams 25 percent negligent for failing to make sure she had enough gas. Williams appealed, arguing her negligence was not a proximate cause of the crash as a matter of law.

Whether proximate cause requires proof both that the negligent act was a cause in fact of the injury and that the resulting type of harm was reasonably foreseeable.