Car Accident Report: SR-520 Multi-Car Rear-End Collision

In November 2005 at approximately 5:15 p.m. SM was traveling along State Route 520 nearing Interstate 405. As she was stopped in traffic, she was unexpectedly struck from behind by KH. The impact then pushed SM’s vehicle into the car directly ahead of her. She recalls feeling multiple impacts during this multi-car collision. Washington State Patrol responded to the collision and upon investigation cited your insured for his negligence - speed too fast for conditions. (See Exhibit 1 – Accident Report)

Substantial damage was done to the rear and front of SM’s 1997 Dodge Caravan. Repair costs exceeded $4,500 and the vehicle was subsequently deemed a “total loss” by the insurance company.

Washington law provides that the drivers on the road have the duty to exercise ordinary care and avoid causing a collision. See RCW 46.61.445 and Washington Pattern Jury Instruction (WPI) 70.01. KH was negligent when he failed to be attentive while driving his vehicle, watch for traffic and otherwise obey the rules of the road. SM did nothing to contribute to the cause of the crash and could do nothing to avoid the collision. As a direct result of KH’s negligence, SM sustained injuries to her neck, back, teeth, and associated body structures.

A summary of her injuries and treatment are outlined below.
  • Cervical strain/sprain and subluxations with in tenderness, pain, muscle spasms, and limited range of motion. Whiplash injury with resultant ligamentous instability and acceleration of spinal disc disease.
  • Back strain/sprain and subluxations with tenderness, pain, muscle spasms, and limited range of motion (thoracic and lumbar regions) resulting in ligamentous instability, acceleration of spinal disc disease and pain radiating down leg periodically.
  • TMJ / jaw pain with discomfort, tenderness and clicking/popping noise
  • Post traumatic stress disorder with symptoms to include increased anxiety, stress, depression, and uncontrollable emotions
  • Headaches
  • Sleep disturbances/fatigue

SM is a 38 year old married woman and mother of three young children. She enjoys spending time with her family and friends and being active outdoors. Other hobbies include home improvements/renovations, hiking, working out at gym, jogging, gardening, reading, music, and movies.

SM has experienced, and continues to experience, a significant loss of enjoyment of life. She was fairly healthy before the collision and since then has not as active as she was before. She must perform daily exercises at home just to manage/maintain her symptoms and avoid flare ups.

SM now seeks damages incurred as a direct result of the injuries she sustained in the collision. In order to ensure that she received sufficient compensation for her medical expenses and loss of enjoyment of life, SM hired Seattle car accident lawyer and personal injury attorney Chris Davis. Mr. Davis is the founder and principal attorney of Seattle-based Davis Law Group and has had substantial success negotiating with Clarendon National Insurance claims representatives for just reimbursement and financial compensation.