Annotated sample complaint: three-vehicle chain collision
Three cars are in a line in New York City traffic. The plaintiff's car, at the front, is stopped. It is struck from behind in a chain collision involving the two cars behind it: the first defendant's car directly behind, and the second defendant's car behind that. Each defendant owns the car he or she was driving. The plaintiff sues both defendants in the Supreme Court for personal injuries and for the damage to the car, without knowing the exact order of the impacts. No city vehicle, rideshare, or passenger is involved.
This sample is also available as a Word file with the blanks highlighted and no notes.
Reading this sample
- The left column is sample text. Words in brackets, like [plaintiff's full name], are blanks. Everything else is the sample wording, which may or may not fit a particular accident.
- The right column explains, in general terms, what each paragraph is for and which rules it relates to. It is the same for every reader and does not say whether any paragraph fits a particular case.
- Each sample fits only the situation described at its top. Paragraphs for other situations, such as passengers, intersections, city vehicles, rideshares, and family members' claims, are in the paragraph catalog.
- Several rules for car accident lawsuits changed for cases started on or after May 26, 2026. The notes describe the rules for those cases; complaints filed earlier, including ones viewed in the court's filing system, may reflect the older rules.
Caption
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF [COUNTY NAME]
COMPLAINT
With two defendants, both names appear in the caption, joined by "and", and the label below them becomes "Defendants." A complaint's caption must name every party (CPLR 2101(c)). People who may be responsible for the same accident can generally be sued together in one case (CPLR 1002(b)), so the claims do not have to be split into separate lawsuits.
Opening paragraph
Plaintiff [plaintiff's full name], appearing pro se, alleges upon information and belief, except as to matters within the personal knowledge of Plaintiff, as follows:
The same opening as in the two-vehicle sample. It names only the plaintiff; the defendants are identified in the paragraphs that follow. With more than one plaintiff, "Plaintiff" becomes "Plaintiffs" and "alleges" becomes "allege."
The parties
At all times relevant herein, Plaintiff [plaintiff's full name] was and remains a person entitled to maintain this action.
The same paragraph as in the two-vehicle sample. The plaintiff here is an adult driver suing in his or her own name; the catalog has paragraphs for a child plaintiff and for a passenger.
At all times hereinafter mentioned, Plaintiff [plaintiff's full name] was and still is a resident of the State of [state where the plaintiff lives].
The plaintiff's residence, stated as of the time the case is started. Like each defendant's residence, it bears on venue (CPLR 503(a)).
At all times hereinafter mentioned, Defendant [first defendant's full name] was and still is a resident of the State of [state where the first defendant lives].
Each defendant gets a separate residence paragraph. With several defendants there may be more than one county where venue is proper, since the residence of any party can support venue (CPLR 503(a)).
At all times hereinafter mentioned, Defendant [second defendant's full name] was and still is a resident of the State of [state where the second defendant lives].
The second defendant's residence. Each defendant must be served with the summons and complaint separately; for an individual, the methods are listed in CPLR 308. A defendant who lives outside New York can generally still be sued here over an accident that happened in New York (CPLR 302(a)).
Jurisdiction and venue
This Court has jurisdiction over the parties and the subject matter of this action, and venue is properly laid in [county where the case is filed] pursuant to CPLR 503, based upon the residence or principal office of one or more of the parties and/or the county in which a substantial part of the events giving rise to the claims occurred.
The same paragraph as in the other samples. It refers to "one or more of the parties," so it works with several defendants. Venue is generally proper in a county where any party lived when the case began, or where a substantial part of the events happened (CPLR 503(a)).
The vehicles and their owners
At all times hereinafter mentioned, Plaintiff [plaintiff's full name] was the owner of the motor vehicle bearing [state that issued the plaintiff's plate] State license plate number [plaintiff's license plate number] involved in the occurrence alleged herein.
Identifies the plaintiff's car by its license plate. In a multi-vehicle accident, naming each vehicle by its plate keeps the allegations about each one distinct. Ownership matters mainly for the property-damage claim.
At all times hereinafter mentioned, Defendant [first defendant's full name] was the owner of the motor vehicle bearing [state that issued the first defendant's plate] State license plate number [first defendant's license plate number] operated by said Defendant and involved in the occurrence alleged herein.
Ownership of the first defendant's car, the one directly behind the plaintiff. In this sample each defendant both owned and drove a car; when an owner and a driver differ, the catalog's separate-owner paragraphs are used for that vehicle.
At all times hereinafter mentioned, Defendant [second defendant's full name] was the owner of the motor vehicle bearing [state that issued the second defendant's plate] State license plate number [second defendant's license plate number] operated by said Defendant and involved in the occurrence alleged herein.
The same paragraph for the second defendant's car, the third car in line. The police accident report usually lists each vehicle's plate, registered owner, and insurer, and is the common source for these details.
At all times hereinafter mentioned, Defendant [first defendant's full name] owned, operated, maintained, controlled, repaired, and used the motor vehicle bearing [state that issued the first defendant's plate] State license plate number [first defendant's license plate number] involved in the occurrence alleged herein.
Alleges ownership and operation of the first defendant's car. A vehicle's owner is generally responsible for negligence of anyone driving it with the owner's permission (Vehicle and Traffic Law § 388 Evidence).
At all times hereinafter mentioned, Defendant [second defendant's full name] owned, operated, maintained, controlled, repaired, and used the motor vehicle bearing [state that issued the second defendant's plate] State license plate number [second defendant's license plate number] involved in the occurrence alleged herein.
The same allegation for the second defendant's car. Each vehicle is usually covered by its own insurance policy, so more than one insurer is commonly involved in a multi-vehicle case.
How the accident happened
On or about [date of the accident], at approximately [approximate time], at or near [street address or intersection where the accident happened], a motor vehicle collision occurred involving Plaintiff and one or more motor vehicles, including the motor vehicle bearing [state that issued the first defendant's plate] State license plate number [first defendant's license plate number].
States when and where the collision happened. The paragraph names one other vehicle, here the first defendant's, and the paragraphs below identify the rest. A driver involved in an accident with injury, or property damage over $1,000, generally must file a report with the Department of Motor Vehicles within 10 days (Vehicle and Traffic Law § 605).
At the time of the occurrence, Plaintiff's vehicle bearing [state that issued the plaintiff's plate] State license plate number [plaintiff's license plate number] was stopped or otherwise stationary, and Defendant [first defendant's full name] failed to operate the following vehicle bearing [state that issued the first defendant's plate] State license plate number [first defendant's license plate number] with reasonable care so as to avoid striking Plaintiff's vehicle.
Alleges that the plaintiff's car was stopped and the car directly behind it failed to avoid striking it. A following driver must keep a reasonable and prudent distance (Vehicle and Traffic Law § 1129(a) Evidence). In chain collisions, a middle driver often says the car was pushed forward by the car behind it; courts then look closely at the order of the impacts.
The occurrence was caused, in whole or in part, by the negligent operation of the vehicle operated by Defendant [first defendant's full name] bearing [state that issued the first defendant's plate] State license plate number [first defendant's license plate number], including failing to maintain a reasonably safe distance and failing to avoid the collision with Plaintiff's vehicle bearing [state that issued the plaintiff's plate] State license plate number [plaintiff's license plate number] under the circumstances then and there existing.
Describes the driving of the car that struck the plaintiff's car directly. The next paragraph addresses the other car in the chain. A complaint states facts rather than evidence; the proof comes later through documents, testimony, and discovery.
Plaintiff alleges that the occurrence involved multiple motor vehicles and that the vehicles came into contact during a sequence of impacts, including the motor vehicle bearing [state that issued the second defendant's plate] State license plate number [second defendant's license plate number]. Plaintiff further alleges that the respective acts and omissions of the Defendant or Defendants, including the manner in which the vehicles were operated, followed, stopped, slowed, controlled, and/or maintained, contributed to the occurrence and to the injuries and damages alleged herein. The sequence, positions, movements, points of impact, and respective causal contributions of the vehicles involved are matters to be determined from the evidence.
Used when three or more vehicles collided in sequence. It identifies the second defendant's car and alleges that each defendant's driving contributed, while leaving the order of the impacts and each vehicle's share of fault to be decided on the evidence. That approach is common when the plaintiff, in the front car, could not see what happened behind. The catalog has versions for a plaintiff whose car was in the middle or at the back of the line.
First cause of action: personal injury
AS AND FOR A FIRST CAUSE OF ACTION
ON BEHALF OF PLAINTIFF [PLAINTIFF'S FULL NAME]
(Negligence: Personal Injury)
Plaintiff [plaintiff's full name] repeats, reiterates, and realleges each and every allegation set forth above with the same force and effect as if fully set forth herein.
The first claim is for the plaintiff's injuries, brought against both defendants. The "repeats and realleges" sentence brings in all the facts alleged above, including those about each defendant.
Plaintiff alleges that, at the time of the occurrence, a motor vehicle, bicycle, device, or other instrumentality involved in the occurrence came into contact with the person of Plaintiff [plaintiff's full name], and that such contact caused and/or contributed to the personal injuries alleged herein.
Alleges that the plaintiff was physically struck or jolted and that this caused the injuries. In a chain collision a person may be jolted more than once; medical records and the timing of symptoms are commonly used to connect injuries to the accident.
As a result of the occurrence, Plaintiff [plaintiff's full name] sustained physical injuries and associated pain, suffering, limitations, and other damages to the extent established by the evidence.
A general statement that the plaintiff was injured. The details usually come later in a bill of particulars and medical records; the catalog has more specific paragraphs for injuries, treatment, expenses, and lost earnings.
The occurrence and resulting injuries were caused solely by the negligence, carelessness, and recklessness of the Defendant or Defendants, without any negligence or culpable conduct on the part of Plaintiff [plaintiff's full name] contributing thereto.
States that the plaintiff was not at fault; it refers to "the Defendant or Defendants" so it works with several. For car accident injury lawsuits started on or after May 26, 2026, a plaintiff whose share of fault is greater than the combined share of all the defendants cannot recover, and a smaller share reduces the award (CPLR 1411(b) Evidence). Like every allegation, it is subject to the signer's certification that it is not frivolous (22 NYCRR 130-1.1a).
Plaintiff [plaintiff's full name] sustained a serious injury as defined in Insurance Law § 5102(d) and/or economic loss greater than basic economic loss as defined in Insurance Law § 5102(a).
By reason of the foregoing, Plaintiff [plaintiff's full name] has been damaged in an amount that exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction.
The same no-fault rules apply as in the two-vehicle sample: pain and suffering can be recovered only for a "serious injury" (Insurance Law § 5102(d) Evidence), and economic loss only above what no-fault insurance covers (Insurance Law § 5104(a) Evidence). For cases started on or after May 26, 2026, the 90-of-180-days category of serious injury was removed, and pain-and-suffering damages are capped at $100,000 for some at-fault plaintiffs (Insurance Law § 5104(d)). No dollar amount is stated for personal injuries (CPLR 3017(c)).
Second cause of action: property damage
AS AND FOR A SECOND CAUSE OF ACTION
ON BEHALF OF PLAINTIFF [PLAINTIFF'S FULL NAME]
(Negligence: Property Damage)
Plaintiff [plaintiff's full name] repeats, reiterates, and realleges each and every allegation set forth above with the same force and effect as if fully set forth herein.
The claim for damage to the plaintiff's car, against both defendants. The no-fault "serious injury" rule does not apply to property damage.
As a result of the negligence of the Defendant or Defendants, the motor vehicle and/or other personal property of Plaintiff [plaintiff's full name] was damaged, and Plaintiff [plaintiff's full name] sustained property damage, including the cost of repair or replacement, loss of use, and related expenses, to the extent established by the evidence.
By reason of the foregoing, Plaintiff [plaintiff's full name] has been damaged in an amount to be determined at trial.
Covers repair or replacement costs and loss of use. When a car is struck more than once, repair records and photographs are commonly used to show which damage came from which impact, although the complaint itself does not divide it.
Closing paragraphs
By reason of the foregoing, the liability of the Defendant or Defendants is joint and several. To the extent any Defendant seeks the benefit of CPLR Article 16, Plaintiff alleges that Article 16 does not limit liability herein, including under the exceptions set forth in CPLR 1602, and that Plaintiff is entitled to recover the full amount of damages from each Defendant found liable.
This paragraph matters most when there are several defendants. CPLR 1601 can limit a defendant who is 50 percent or less at fault to that share of non-economic damages, but CPLR 1602 makes exceptions, including for people held liable because of the use, operation, or ownership of a motor vehicle. "Joint and several" liability means the plaintiff can generally collect the whole judgment from any liable defendant, who may then seek contribution from the others (CPLR 1401).
WHEREFORE, Plaintiff demands judgment against the Defendants as follows:
(a) On the First Cause of Action, on behalf of Plaintiff [plaintiff's full name], for personal injuries, in an amount that exceeds the jurisdictional limits of all lower courts that would otherwise have jurisdiction;
(b) On the Second Cause of Action, on behalf of Plaintiff [plaintiff's full name], for property damage, in an amount to be determined at trial; and
(c) The costs and disbursements of this action, together with interest as permitted by law, and such other and further relief as this Court deems just and proper.
The demand is made against both defendants ("the Defendants"). As in the two-vehicle sample, there is one lettered item per cause of action plus costs and interest, and no dollar figure for personal injuries (CPLR 3017(c)).
Dated: [county where the complaint is signed] County, New York
____________________, 20____
The place and date of signing. The date is usually filled in by hand when the final version is signed.
______________________________
[PLAINTIFF'S FULL NAME]
Plaintiff pro se
[plaintiff's mailing address]
Telephone: ____________________
Email: ____________________
The plaintiff signs personally, with the name printed below the signature (22 NYCRR 130-1.1a(a)), and lists an address and telephone number (CPLR 2101(d)). Once the defendants appear in the case, later papers are generally served on every party who has appeared (CPLR 2103(e)).
What this sample leaves out
- The summons, which names every defendant and is served on each one (CPLR 304, 305, 308).
- Cross-claims. Each defendant's answer may include claims against the other defendant, for example for contribution (CPLR 3019(b)).
- Paragraphs for a plaintiff whose car was in the middle or at the back of the line, for vehicles whose owner and driver differ, and for passengers in any of the cars. These are in the catalog.
- A notice of claim, which is generally required within 90 days before suing New York City or another public entity (General Municipal Law § 50-e Evidence).
- A verification (CPLR 3020), a jury demand (CPLR 4102), proof of service, and later papers such as a bill of particulars.
Other sample paragraphs are in the paragraph catalog. Other samples: two-vehicle rear-end collision; pedestrian struck in a crosswalk.
Last reviewed October 2026. Sample text is general and may be out of date.