National Bank of Bloomington v. State

In National Bank of Bloomington v. State (1980), 34 Ill. Ct. Cl. 23, the proximate cause was clearly and easily established. The occurrence eyewitness testified that there were 8 to 10 inches of water on the roadway and that he witnessed the decedent's vehicle come into contact with the water, hydroplane, leave the pavement, come out of a ditch, and crash into his truck head on. In that case local residents testified that they had observed water accumulating on the roadway numerous times. In the National Bank of Bloomington case, Trooper Hinkle testified that he had driven over the area numerous times and had seen water standing on the same site on prior occasions. He further testified that in the past, he had signs posted at the site of that accident when he had noticed water standing on the roadway.