Sample Auto Accident Complaint for Whiplash Injury


    • Plaintiff Rick Flint (“Flint”) is a resident of Richmond, Virginia.
    • Defendant John Rogers (“Rogers”) is a resident of Midlothian, Virginia.
    • The amount in controversy satisfies the jurisdictional requirements of this Court
    • Venue is proper in this Court. This action arises out of a motor vehicle accident that occurred in Richmond, Virginia.


  • Flint incorporates by reference paragraphs 1 through 4.
  • On February 1, 2016 at 9:00 AM, Flint was driving a motor vehicle he owned and operated (the “Flint Vehicle”) on West Broad Street.
  • At that time and place Rogers was operating a motor vehicle he owned and operated (the “Rogers Vehicle”). Rogers operated the Rogers Vehicle negligently, causing it to strike the rear of the Flint Vehicle.
  • Rogers owed Flint a duty to exercise reasonable care when operating the Rogers Vehicle. Rogers breached that duty when he failed to operate the Rogers Vehicle in a reasonable and prudent manner.
  • Rogers’s breach of duty was the direct and proximate cause of injuries suffered by Flint in the collision of the Rogers Vehicle with the Flint Vehicle. Flint suffered severe injuries and damages, including hyperextension of the cervical spine causing a deceleration injury impact to Flint as the Flint Vehicle was struck from the rear. Flint’s neck musculature extended beyond normal physiological limits in the collision, which caused spasm, edema, and pain. Flint also sustained and suffered symptoms that have been documented by objective clinical evidence, including x-ray, MRI changes, loss of lordotic curvature, loss of physical function of the cervical spine, and permanent physical impairment.
  • The injuries mentioned above have caused Flint to require substantial medical treatment, wage loss, a loss of earnings, pain, and suffering.
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