Plaintiff Tommie Hampton was injured in a head-on collision with Defendant Jeffrey Madden, who was driving recklessly in the wrong direction on an exit ramp of I-40/240 while allegedly fleeing from Memphis police. Hampton filed a negligence lawsuit against Madden and the City of Memphis under the Governmental Tort Liability Act, claiming the police's pursuit contributed to the incident. The trial court determined that Hampton's injuries were solely caused by Madden's actions, not the police, and ruled in favor of the City. The court dismissed claims against the police officers and limited Hampton's damages to $250,000, as permitted by the GTLA. Following a three-day trial, the court found that the injuries resulted from Madden's criminal behavior. Hampton's post-trial motion to amend findings was denied, leading to his appeal. The Court of Appeals affirmed the trial court's judgment, citing that the injuries were not a result of police negligence.
The trial court's February 2010 order was found not to be a final judgment as it did not resolve Mr. Hampton's claim against Mr. Madden or his motion for an adverse inference against the City. An order was issued for Mr. Hampton to explain why the appeal should not be dismissed due to this lack of a final judgment. Subsequently, the trial court granted a voluntary non-suit against Mr. Madden and denied Mr. Hampton's motion for an adverse inference, rendering the order final.
Mr. Hampton raised five issues on appeal, with the primary focus being whether the trial court erred in concluding that the City police officers' actions were not the proximate cause of Mr. Hampton's injuries from a collision with Mr. Madden's vehicle. Causation is treated as a question of fact, with the appellate court reviewing factual findings de novo but presuming their correctness unless the evidence suggests otherwise.
The elements of negligence include a duty of care, breach of duty, injury, causation in fact, and proximate cause. In this case, the trial court's determination centered on breach of duty and causation. The court found no breach of care and ruled in favor of the City, establishing that the police actions did not proximately cause Mr. Hampton's injuries. The appellate review is limited to assessing whether Mr. Hampton met his burden of proof regarding causation, which consists of both cause in fact and proximate cause. These are typically factual questions for the trier of fact unless the facts lead to an uncontested conclusion.
Causation in fact requires the plaintiff to demonstrate that the defendant’s actions directly contributed to the injury, established by the 'but for' test, meaning the injury would not have occurred without the defendant's conduct. The defendant's actions must be a cause, though not necessarily the sole cause. Proximate cause, which deals with legal liability, limits the causation chain, indicating that a defendant is not liable for injuries that are not substantially caused by their conduct or are not reasonably foreseeable results. A three-pronged test for proximate cause includes: (1) the defendant's conduct must be a 'substantial factor' in causing the injury; (2) no rule or policy should relieve the wrongdoer from liability; and (3) the harm must be foreseeable to a person of ordinary prudence.
In the case at hand, Mr. Madden, under the influence of drugs and unfamiliar with the area, collided with Mr. Hampton while driving the wrong way on an exit ramp. Despite his claims regarding the police officers’ pursuit, the trial court found Mr. Madden's lack of credibility and concluded that the actions of the undercover police did not legally cause the collision. The court emphasized that Mr. Hampton’s severe injuries resulted from Mr. Madden's criminal behavior rather than the police pursuit. Mr. Madden’s testimony indicated he was trying to evade the unmarked truck, but he was unaware of his surroundings and did not see the police until it was too late. Mr. Hampton contested the trial court's finding, arguing that police pursuits leading to third-party injuries are well-documented in Tennessee. However, the evidence supported the trial court's conclusion that the police actions were not the proximate cause of Mr. Hampton's injuries.
Unrebutted expert testimony indicates that a criminal suspect typically flees from police until escape or collision occurs and drives safely when not being chased. Mr. Hampton argues that Mr. Madden's flight was typical and led to a collision, but evidence does not support that Mr. Madden was aware he was being pursued by police when he made a U-turn at the Warford Street exit. Mr. Madden testified he did not recognize the pursuing pickup truck as police and felt no reason to stop. He stated that he made the U-turn without realizing the truck was behind him and did not see marked police cars until moments before the collision, during which he did not brake because he lacked time to react. Undercover officer Mr. Teeters confirmed that the unmarked pickup truck was several car lengths behind when Mr. Madden turned and that he did not see Mr. Hampton’s vehicle until just before impact. Teeters opined that Mr. Madden was unaware he was being followed, as there were no sirens or lights indicating police presence. The court found that Mr. Madden independently decided to make the U-turn before noticing the unmarked police vehicle and believed he had lost it, intending to flee back to Arkansas. The trial court noted Mr. Madden had consumed drugs prior to the incident. It dismissed the suggestion that Mr. Madden drove faster upon realizing the truck was behind him as implausible based on the officers’ testimonies and the evidence. Ultimately, the court affirmed the trial court’s judgment, stating that there was no clear evidence contradicting its factual findings regarding causation, and dismissed additional issues raised by Mr. Hampton. Costs of the appeal were assigned to Mr. Hampton and his surety.
