Pratt v. Thomas
In Pratt v. Thomas, 80 Wn.2d 117, 491 P.2d 1285 (1971), the defendant left a station wagon, without the ignition locked, in a high school parking lot.
Three high school students stole the vehicle. The students drove the vehicle for "some distance . . . and drove to the home of another boy." Pratt, 80 Wn.2d at 118.
"After the students had driven the stolen vehicle for a while, the state patrol saw it and pursued. A high speed chase followed. The accident occurred and the plaintiffs were injured." Id. at 118.
The trial court dismissed the plaintiffs' complaint and they appealed.
Without resolving the question of duty, the Court held, as a matter of law, that the defendant's negligence was not the proximate cause of plaintiff's injuries:
Here it is plain the accident which caused plaintiff's injuries was not a part of the natural and continuous sequence of events which flowed from defendant's act in leaving their station wagon in the parking lot. It was the result of new and independent forces. Among the new forces were the stealing of the vehicle, the pursuit by the state patrol, the attempt by the thieves to run from the officers and, finally, the accident.
When, as here, the facts do not admit of reasonable differences of opinion, proximate cause is a question of law to be decided by the court. Id. at 119.