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A recent case suggests the applicability of the doctrine of res ipsa loquitur to airplane accidents and thus raises occasion for speculation as to the future development of the law in this direction. In Sollak v. New York, plaintiff recovered for personal injuries received in a collision between an airplane and an automobile. The evidence disclosed that while the automo- bile in which plaintiff was riding was proceeding along a public highway near a flying field, a plane operated by defendant's officer collided with the automobile producing the injuries complained of. This, together with proof of the nature and extent of the injuries constituted all the evidence. Plaintiff contended that in the absence of any explanation on the part of the state as to how the collision occurred, the doctrine of res ipsa loguitur must be applied. It seems that the doctrine was applied.

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Res Ipsa Loquitur in Air Law, 1 Air Law Review 478 (1930)

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