Defendant X owned a non-registered automobile which was parked on a public way by defendant Y, an agent of X. The keys were left in the car in violation of a statute. Later in the same day the car was stolen. Plaintiff, a pedestrian, was injured by the thief's negligent operation of the car. In an action to recover for the injury, a verdict was directed for defendants. On appeal, held, affirmed. As a matter of law, defendant's action in allowing a non-registered automobile containing its keys to remain on a public way was not the proximate cause of plaintiff's injury. Galbraith. v. Levin, Galbraith v. Cohen, (Mass. 1948) 81 N.E. (2d) 560.
Richard B. Gushée,
NEGLIGENCE--PROXIMATE CAUSE--EFFECT OF NON-REGISTRATION OF AUTOMOBILE,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol47/iss4/18