Palm Beach County Board of Commissioners v. Salas

In Palm Beach County Board of Commissioners v. Salas, 511 So. 2d 544 (Fla. 1987), the Court was asked to determine whether a county work crew could be held liable for failing to take reasonably necessary steps at a maintenance site to protect the safety of passing motorists. In that case, a survey crew had blocked a left turn lane, rendering the left turn signal perpetually red. See: id. at 545. The crew failed to post signs prohibiting left turns from the remaining lanes. See: id. A woman who attempted to turn from the far right lane collided with the plaintiffs in the intersection. See: id. The Court held that the work crew had a duty to carry out its maintenance responsibilities in a non-negligent manner, and had a duty to warn the motoring public of any known hazards that the presence of the work crew, blocking of the turn lane, and accompanying deactivation of the turn signal had created. See: id. at 547.