Woodward v. Taylor – Jurisdiction and Statute of Limitations

In most car accident lawsuits, the issue of jurisdiction is a straightforward one.snowhighway

Jurisdiction is the power of a court to hear and decide a particular case. Parameters are set by federal and state laws, and require the court to have both personal jurisdiction and subject matter jurisdiction. Personal jurisdiction is the power to preside over an individual, while subject matter jurisdiction is the power to preside over a particular kind of case.

When it comes to crash cases, typically the case will be filed in the state where the accident occurred, though there are sometimes exceptions. Establishing jurisdiction early on is critical because it can affect the amount of time in which one has to file a lawsuit (statute of limitations) and also applicable proof burdens, both of which can vary from state-to-state and jurisdiction-to-jurisdiction. 

In the recent case of Woodward v. Taylor, the issue of jurisdiction was in dispute.

According to court records in this traffic accident case, the Washington Supreme Court was asked to weigh whether Washington state courts had jurisdiction over a car accident lawsuit stemming from a crash in Idaho. The answer was critical because in Idaho, the statute of limitations for personal injury lawsuits is two years, but in Washington, it’s three years. Plaintiff filed the case little more than two years after the crash.

The accident happened in 2011. Defendant was driving a car with plaintiff and two others as passengers. The group was returning to Washington, where they all resided, after a trip to Nevada. They were driving through Idaho, and the road was slippery with ice and there was snow piled up on the side of the road.

Even though these were potentially dangerous road conditions that warranted the driver to slow down, she set her cruise control at 82 mph – 7 mph above the legal speed.

Around 2:30 a.m., defendant lost control of the vehicle, and it rolled over. Plaintiff, who was asleep in the backseat and wearing a seat belt, sustained severe injuries that included a neck fracture.

In 2013, more than two years after that crash, plaintiff filed her lawsuit against defendant in Washington state, alleging liability based on the fact defendant was driving too fast for road conditions and caused the crash.

Defendant moved to dismiss on statute of limitation grounds, arguing a negligence action based on rules of the road is subject to the law of the state where the crash occurred – and Idaho’s statute of limitations had expired.

Trial court agreed and an appellate court affirmed. Plaintiff appealed to the state supreme court, which reversed.

The state supreme court ruled there was no conflict of law between the Idaho and Washington (it did not consider the statute of limitations as a source of conflict), and therefore Washington courts had jurisdiction (and the case wasn’t time-barred).

There was no conflict of law when came to general negligence, maximum speed law or comparative fault laws.

Had there been an actual conflict, the court would have needed to apply the “most significant relationship test,” in which it would weigh the interest parties had with each jurisdiction. This test takes into effect where the parties live and where the alleged negligence occurred. But that wasn’t necessary because no conflict existed.

Contact the Carolina injury lawyers at the Lee Law Offices by calling 800-887-1965.

Additional Resources:

Woodward v. Taylor, January 2016, Washington State Supreme Court

More Blog Entries:

High-Profile Fatal Accidents in Carolinas Over Holidays, Jan. 7, 2016, Rock Hill Traffic Accident Lawyer Blog

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