In Sanford v. Stillitano (241 AD2d 489, 660 N.Y.S.2d 67 [2d Dept 2010], the appellants' vehicle was the middle vehicle in a three-car collision on the Verrazano Narrows Bridge, and the appellants argued that they were entitled to summary judgment because their vehicle was hit from behind while lawfully stopped in traffic waiting to exit the bridge.

The Appellate Division, Second Department, affirmed denial of summary judgment because "there was evidence suggesting that the appellants had been following the car driven by the defendant John Stillitano too closely and at too great a speed, and that the appellants and Stillitano stopped abruptly." (Id.)