This page summarizes and comments on a published court decision. It is general information, not legal advice, and reading it does not create an attorney-client relationship. Every case depends on its own facts. Unless this page says otherwise, The Eskesen Law Firm did not represent any party in this case.
Bottom line
A driver turning left must generally yield to oncoming traffic, but a driver with a green light must also yield to other traffic lawfully within the intersection, so a left turn does not automatically mean the turning driver was at fault. Here, the First Department reinstated a left-turning driver’s claim because the record did not conclusively show which driver had to yield after a concrete truck blocked the intersection.
The case
- Court
- Appellate Division, First Department
- Decided
- October 20, 2026
- Case
- Sanchez-Rodriguez v Bruce
- Citation
- 2026 NY Slip Op 06077
- Official text
- Read the decision on the New York courts’ official reporter site
The facts
As the decision describes the testimony, on May 24, 2018, the plaintiff’s and the defendant’s vehicles collided at Grant Highway and West 169th Street in the Bronx. The plaintiff testified that a concrete truck was blocking traffic coming from the opposite direction, and that when the light turned green he turned left, proceeding carefully by the side of the stationary truck at five miles per hour or less; the truck blocked his view, and he had almost completed the turn when he first saw the defendant’s vehicle, which hit his car two seconds later. The defendant testified that he was driving straight with a green light, moved partially into the bicycle and parking lanes to avoid the truck, which was in reverse, drove below the speed limit, and did not see the plaintiff’s vehicle before the impact. The Supreme Court, Bronx County, granted the defendant summary judgment dismissing the complaint against him, and the plaintiff appealed.
The holding
The First Department unanimously reversed and reinstated the complaint. The defendant made his first showing: he testified that he was driving straight, below the speed limit, with a green light, when the plaintiff’s left-turning vehicle failed to yield, and photographs showed he was close enough to be an “immediate hazard” under Vehicle and Traffic Law § 1141 (2026 NY Slip Op 06077, *2). But under § 1111, traffic facing a green light must yield to other traffic lawfully within the intersection, and the plaintiff testified that he had almost completed his turn. “The evidence does not conclusively establish which vehicle was required to yield” (id.). Both drivers said the truck blocked their view, and on the plaintiff’s argument under § 1143 that the defendant entered the roadway from the bicycle and parking lanes, “the record does not provide conclusive evidence of each vehicle’s location leading up to the accident and which party ultimately had a duty to yield” (id.).
What changed
Nothing new: this applies settled law, including the court’s earlier decisions in Palau v Pagan (194 AD3d 425) and Crespo v New York City Hous. Auth. (222 AD2d 300).
What it means
- Under Vehicle and Traffic Law § 1141, a driver turning left “shall yield the right of way to any vehicle approaching from the opposite direction which is within the intersection or so close as to constitute an immediate hazard.”
- But under § 1111(a)(1), traffic facing a steady green light “shall yield the right of way to other traffic lawfully within the intersection or an adjacent crosswalk at the time such signal is exhibited.” When the rules point in different directions and the record does not clearly show where each vehicle was, who had to yield may be a question for trial.
- This is an older action, so pure comparative fault applies. For motor vehicle actions commenced on or after May 26, 2026, that fall under the new law, a plaintiff found more at fault than the defendants cannot recover (see our post on New York’s 2026 changes).
Our view
Commentary by Frank N. Eskesen. This section is opinion.
Compare our entry on Hyejun Cho v NYCTA (Second Department, October 7). There, bus video conclusively established that a car’s driver, who turned left into the bus’s path, was the sole proximate cause, and a passenger’s claims against the Transit Authority and its bus driver were dismissed. Here, the decision describes no such proof: both drivers said a truck blocked their view, and the record did not conclusively show where each vehicle was. The court did not decide that the plaintiff was free of fault; it held only that who had to yield could not be decided on these papers. In our experience, a driver who begins a left turn on a green light may have to stop partway through, for example for a pedestrian stepping into the crosswalk, and an oncoming driver who is looking elsewhere, rather than at the car already in the intersection, may still be responsible for the crash. That is the rule the plaintiff relied on here: a driver facing a green light must still yield to other traffic lawfully within the intersection. We believe two lessons follow. 1. After a crash at an intersection, take photographs showing where the vehicles ended up and any truck or other obstruction, and get legal advice promptly; the court here relied in part on photographs. 2. For lawyers, in a left-turn case, look for every rule that may apply to the other driver, including the duty to yield to traffic already lawfully in the intersection. A left turn is where the fault question starts, not where it ends.
Topics
Court: First Department. Year: 2026. Statutes: Vehicle and Traffic Law §§ 1111, 1141, 1143. Result: reversed.
Reviewed by Frank N. Eskesen, admitted in New York since 2000. Decided October 20, 2026. Posted October 20, 2026.
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