Does a jury have to determine that negligence was not a proximate cause of a motor vehicle accident?

Two analogous New York cases illustrate this point. In Browne v. Pikula (1998) 682 N.Y.S.2d 750 [256 A.D.2d 1139] (Browne), the jury found that the defendant negligently caused an automobile accident, but determined the negligence was not a proximate cause of the plaintiff's injuries. (Ibid.) The trial court set aside the verdict as against the weight of evidence on the issue of proximate cause. (Ibid.) "Although the medical experts disagreed concerning the extent to which the accident caused

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