SeeBanner v. Raisin Valley, Inc. , 31 F.Supp.2d 591, 593–94 (N.D. Ohio 1998). For instance, if the driver maintained or regained control of his or her vehicle before going on to hit a second car (or to hit the first again), the collisions can be deemed separate accidents. SeeLiberty Mut. Ins. Co. v. Rawls , 404 F.2d 880, 880–81 (5th Cir. 1968) (per curiam) (finding that two accidents occurred for purposes of liability limit where the insured struck two vehicles with a five-second interval between the collisions while fleeing from law enforcement because there was no evidence that the insured lost control of his vehicle); Amberge v. Lamb , 849 F.Supp.2d 720, 721–22, 726 (E.D. La. 2011) (finding that four separate accidents occurred where driver impacted other vehicle "at four distinct points in time" and driver had maintained control of his vehicle throughout the impacts); Ill. Nat'l Ins. Co. v. Szczepkowicz , 185 Ill. App.3d 1091, 134 Ill.Dec. 90, 542 N.E.2d 90, 93 (1989) (finding that two accidents had occurred where five minutes elapsed between impacts and negligent driver had moved his vehicle but left it blocking the road after the first collision). As part of this analysis, courts examine the time and space interval between the collisions. Welter v. Singer , 126 Wis.2d 242, 376 N.W.2d 84, 87 (Ct. App. 1985) ("If cause and result are so simultaneous or so closely linked in time and space as to be considered by the average person as one event, courts adopting the ‘cause’ analysis uniformly find a single occurrence or accident."); seeBanner , 31 F.Supp.2d at 593–94 (collecting cases).
See Banner v. Raisin Valley, Inc., 31 F.Supp.2d 591, 593–94 (N.D.Ohio 1998). For instance, if the driver maintained or regained control of his or her vehicle before going on to hit a second car (or to hit the first again), the collisions can be deemed separate accidents. See Liberty Mut. Ins. Co. v. Rawls, 404 F.2d 880, 880–81 (5th Cir.1968) (per curiam) (finding that two accidents occurred for purposes of liability limit where the insured struck two vehicles with a five-second interval between the collisions while fleeing from law enforcement because there was no evidence that the insured lost control of his vehicle); Amberge v. Lamb, 849 F.Supp.2d 720, 721–22, 726 (E.D.La.2011) (finding that four separate accidents occurred where driver impacted other vehicle "at four distinct points in time" and driver had maintained control of his vehicle throughout the impacts); Ill. Nat'l Ins. Co. v. Szczepkowicz, 185 Ill.App.3d 1091, 134 Ill.Dec. 90, 542 N.E.2d 90, 93 (1989) (finding that two accidents had occurred where five minutes elapsed between impacts and negligent driver had moved his vehicle but left it blocking the road after the first collision). As part of this analysis, courts examine the time and space interval between the collisions. Welter v. Singer, 126 Wis.2d 242, 376 N.W.2d 84, 87 (Ct.App.1985) ("If cause and result are so simultaneous or so closely linked in time and space as to be considered by the average person as one event, courts adopting the ‘cause’ analysis uniformly find a single occurrence or accident."); see Banner, 31 F.Supp.2d at 593–94 (collecting cases).
Thus, application of the "causation" theory to the facts of that case would lead to the same result.In Amberge v. Lamb , 849 F.Supp.2d 720 (E.D. La. 2011), a highly intoxicated driver rear-ended a vehicle on the interstate, then, as both vehicles continued to drive forward, switched lanes and rear-ended the same vehicle a second time "thirty seconds to two minutes after the first collision." Id. at 721.