concurrent causation doctrine (Vermont) · Go Syfert
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concurrent causation doctrine in Vermont

7 Vermont opinions name it 1 courts 1997–2011 0 in the last five years

The cases below were cited by Vermont courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
State Farm Mutual Automobile Insurance v. Robertsgreen
vt · 1997 · cited in 5 Vermont opinions naming this issue, 1999–2007
2 sentences

2007Co. v. Roberts, 166 Vt. 452, 459 , 697 A.2d 667, 671 (1997) (for the purposes of the related doctrine of concurrent causation, causes must be independent of each other); Mailhiot v. Nationwide Mut.

2007Co. v. Roberts, 166 Vt. 452, 459 , 697 A.2d 667, 671 (1997) (for the purposes of the related doctrine of concurrent causation, causes must be independent of each other); Mailhiot v. Nationwide Mut.

35
Mailhiot v. Nationwide Mutual Fire Insurancegreen
vt · 1999 · cited in 2 Vermont opinions naming this issue, 2001–2011
2 sentences

2011Co., 169 Vt. 498, 504 , 740 A.2d 360, 364 (1999) (holding that where allegedly covered “act of negligence ... is inseparable from the excluded conduct... the concurrent causation doctrine does not apply”). ¶ 9.

2011Co., 169 Vt. 498, 504 , 740 A.2d 360, 364 (1999) (holding that where allegedly covered “act of negligence ... is inseparable from the excluded conduct... the concurrent causation doctrine does not apply”). ¶ 9.

12
State Farm Mutual Automobile Insurance v. Partridgegreen
cal · 1973 · cited in 2 Vermont opinions naming this issue, 1997–1999
2 sentences

1999In so concluding, we contrasted Roberts with the leading case on concurrent causation, State Farm Mutual Automobile Insurance Co. v. Partridge, 514 P.2d 123 (Cal. 1973), in which an insured modified a pistol to create a hair trigger, which then discharged and injured his friend when the insured drove over a bump.

1997The leading case on the concurrent causation doctrine is State Farm Mutual Automobile Insurance Co. v. Partridge, 514 P.2d 123 (Cal. 1973).

12
Lawver v. Bolinggreen
wis · 1976 · cited in 1 Vermont opinions naming this issue, 1997–1997
1 sentence

1997See Partridge, 514 P.2d at 129 (even assuming automobile exclusion is not ambiguous, coverage exists under homeowner’s policy as long as included risk was concurrent proximate cause of accident); Lawver, 238 N.W.2d at 521 (Partridge did not base its decision on existence of exclusion’s ambiguity, but rather found that included and excluded risks concurred in causing injury). 3 In essence, we accepted the same argument in Valente .

11
Northern Assurance Co. of America v. EDP Floors, Inc.green
md · 1987 · cited in 1 Vermont opinions naming this issue, 1997–1997
1 sentence

1997See Northern Assurance Co. of America v. EDP Floors, Inc., 533 A.2d 682, 689-90 (Md. 1987) (no coverage under general business liability policy for claim of negligent supervision of drunken employee whose operation of hydraulic lift on truck caused injury; policy’s automobile exclusion, which unambiguously denied coverage for injuries “arising out of” use of motor vehicle, did not require that use of truck be sole cause of injury); Vanguard Ins.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Vermont. Read the followed side critically anyway.

Where else courts name it

TX 23 (2005–2025) VT 7 (1997–2011) FL 5 (2001–2016) WA 2 (1993–1995) ME 2 (2020–2022) CA 2 (1989–2007) MS 2 (2009–2010) OH 2 (2005–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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