Very recent blog entries Sixty-One Year Old Woman Killed in Parma, New Yorkand Rear-End Accident Eleven Year-Old Girl Killed in Wellsville, NY, echoed on December 11, 2010 when a pick-up was rear ended by a Chevy Impala on Route 31 in the Town of Sweden, forcing the pick-up into colliding with an oncoming SUV, killing an 81 year-old man and critically injuring three more people.
The driver of the Impala was a 21 year-old woman.
While the Democrat & Chronicle article indicated that "The crash remains under investigation", what I wrote about New York case law concerning rear-end collisions applies in this case. Not maintaining a look-out ahead of your vehicle is a "wrongful act, neglect or default" sufficient to invoke liability for the ensuing accident and the resulting injuries, even death.