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The history of the law governing recovery in automobile cases began long before the time of the automobile. The older doctrine of liability for causing bodily injury directly, even by accident, was strict; the individual acted at his peril. There were suggestions that he might escape liability by showing "inevitable accident," or that the cause of the injury was "utterly without his fault." But it was the defendant's burden to make such a showing, and this was never successfully done in any reported case before the nineteenth century.

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History of the Law Governing Recovery in Automobile Accident Cases, 14 U. Fla. L. Rev. 321 (1962)

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