context: First, in the cases finding proximate cause, there generally was some debris from the first accident still blocking the roadway, while there was not in the cases finding no proximate cause. Second, in the cases finding proximate cause, there generally was only a short time gap between the first accident and the follow-on accident, while in the cases finding no proximate cause there was a substantial time lapse between them.
citation_a.signal: but see
citation_a.parenthetical: finding that 1-hour gap did not ehminate proximate-cause relationship when disabled vehicles continued to block the roadway at the time of the second collision
citation_a.sentence: But see Johnson, 200 Minn. 428 (finding that 1-hour gap did not ehminate proximate-cause relationship when disabled vehicles continued to block the roadway at the time of the second collision).
citation_b.signal: no signal
citation_b.identifier: 66 Ill. App. 2d 407, 411-12
citation_b.parenthetical: finding that a gap of 3 to 10 minutes between accidents was an important factor in finding no proximate-cause relationship between them
citation_b.sentence: Compare Sawdey v. Producers’ Milk Co., 107 Cal. App. 467, 480, 290 P. 684 (1930) (finding that a 3-minute gap between accidents did not eliminate proximate-cause question); and Anderson, 131 Conn. at 238-39 (finding that a gap of 2 to 4 minutes between accidents did not ehminate proximate-cause question); and Krumvieda v. Hammond, 71 S.D. 544, 548-49, 27 N.W.2d 583 (1947) (finding that 2 minutes lapsed time between the first and second accidents did not take proximate-cause issue away from jury consideration) with Millirons v. Blue, 48 Ga. App. 483, 484-85, 173 S.E. 443 (1934) (finding that the first accident was not proximate cause of the second accident occurring 20 minutes later when the damaged vehicle was on the roadway with fights on); and Anderson v. Jones, 66 Ill. App. 2d 407, 411-12, 213 N.E.2d 627 (1966) (finding that a gap of 3 to 10 minutes between accidents was an important factor in finding no proximate-cause relationship between them).