Hughes v. Marley

Supreme Court of Alabama

Tuscaloosa County | No. SC-2023-0009 | Aug. 25, 2023

Appeals Court Reviews Whether Car Accident Caused Victim's Sepsis and Resultant Death

On September 11, 2017, Wilie Hughes was hit by Marley's car but appeared uninjured at the accident scene. Six months later, Willie died from sepsis. In 2020, Dottie Hughes, representing Willie Hughes' estate, filed a wrongful-death lawsuit against Marley under Alabama's wrongful-death statute, citing Marley's negligence and wantonness.

In 2022, Marley sought a summary judgment, contending insufficient evidence linked the accident to Willie Hughes' death and claiming the lawsuit was beyond the two-year statutory period. Marley provided Willie's medical records and Dr. Sheppard's deposition, both suggesting Willie Hughes' death was from natural causes unrelated to the accident. However, Dottie Hughes resisted, highlighting that trauma from car accidents could potentially cause sepsis. The trial court sided with Marley.

Dottie Hughes appealed, arguing the lawsuit was within the time limit and asserting there was a factual dispute regarding the accident's role in Willie Hughes' death. The Appeals Court determined that the lawsuit was timely as the original complaint, filed within two years of Willie Hughes' death, sufficed. However, the crux was if the trial court was right in determining a lack of evidence of causation. Based on Dr. Sheppard's deposition and other evidence, the court found no substantive proof contradicting that the accident was unrelated to Willie Hughes' sepsis and death. Trial court's summary judgment in favor of Marley was affirmed. 

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