context: The analytical distinction between determining whether a licensing requirement establishes a standard of care and determining whether a violation of such a requirement is a proximate cause of plaintiffs injury can often become blurred, and the Virginia courts have been more inclined to resolve negligence per se claims based on licensing requirements by concluding that the violation of a licensing requirement is not a proximate cause of the injury.
citation_a.signal: see
citation_a.parenthetical: finding that the lack of a driver's license, albeit a statutory violation, "did not proximately cause or contribute to the collision"
citation_a.sentence: See Laughlin v. Rose, 200 Va. 127, 104 S.E.2d 782, 786 (1958) (finding that the lack of a driver’s license, albeit a statutory violation, “did not proximately cause or contribute to the collision”); White v. Edwards Chevrolet Co., 186 Va. 669, 43 S.E.2d 870, 871 (1947) (remarking that driving a truck after expiration of a permit did not cause injury, just as “the failure of a competent driver to obtain a chauffeur’s license could not, by any possibility, have contributed proximately to the happening of the automobile collision complained of’ (citations and internal quotation marks omitted)); see also Bentley, 445 S.E.2d at 133 (observing that “[vjiolation of a traffic statute constitutes negligence, but imposition of liability depends on whether that negligence was a proximate cause of the accident”).
citation_b.signal: see also
citation_b.identifier: 445 S.E.2d 133, 133
citation_b.parenthetical: observing that "[vjiolation of a traffic statute constitutes negligence, but imposition of liability depends on whether that negligence was a proximate cause of the accident"
citation_b.sentence: See Laughlin v. Rose, 200 Va. 127, 104 S.E.2d 782, 786 (1958) (finding that the lack of a driver’s license, albeit a statutory violation, “did not proximately cause or contribute to the collision”); White v. Edwards Chevrolet Co., 186 Va. 669, 43 S.E.2d 870, 871 (1947) (remarking that driving a truck after expiration of a permit did not cause injury, just as “the failure of a competent driver to obtain a chauffeur’s license could not, by any possibility, have contributed proximately to the happening of the automobile collision complained of’ (citations and internal quotation marks omitted)); see also Bentley, 445 S.E.2d at 133 (observing that “[vjiolation of a traffic statute constitutes negligence, but imposition of liability depends on whether that negligence was a proximate cause of the accident”).