Sample Auto Accident Complaint

Below is an example complaint in a car accident case.  It is pretty simple, and it should be.  Car accident lawsuits should not be complex or include excessive detail. Complaints are legal pleadings that can be used against you at trial if you overreach.

Sure, a complaint must describe the factual basis for the suit with some degree of factual specificity.  But, ultimately, your purpose is to meet the pleading requirements to state a viable claim.  So all you need to do is list the claims you intend to make and provide sufficient factual allegations to support the claims made.

Also, in Maryland and most jurisdictions, make sure you plead a jury trial in a separate document, assuming you want a jury trial.

Example Car Accident Lawsuit






Mary Ann Johnson, Plaintiff, by Ronald V. Miller, Jr. and Miller & Zois, LLC, her attorneys, sues the defendant, James C. Sexton, and in support, states as follows:


  1. Mary Ann Johnson, the Plaintiff, is a resident of Maryland.
  2. James C. Sexton, the Defendant, is a resident of Maryland.
  3. The Defendant regularly visits and is engaged in business in Baltimore City, Maryland.
  4. This action arises from a car accident that occurred on May 22, 2023, at the intersection of Maryland Route 152 and Rockford Road. Both are public roads in Maryland.


  1. On May 22, 2013, Plaintiff, Mary Ann Johnson, was carefully and prudently stopped in her motor vehicle on Route 152, when her vehicle was violently struck from behind by Defendant.
  2. At the same time, a motor vehicle operated by James C. Sexton, Defendant, was traveling, and smashed into Plaintiff’s vehicle, causing a car accident in which Plaintiff sustained severe personal injuries.


Plaintiff, Mary Ann Johnson realleges and incorporates by reference all those facts and allegations in paragraphs 1 through 6 above and further alleges:

  1. The collision was caused by the recklessness, carelessness, and negligence of Defendant, James C. Sexton, for that among other acts and omissions Defendant:
    1. operated the motor vehicle at a high, dangerous, and excessive rate of speed under the circumstances then and there existing;
    2. failed to reduce speed to avoid a collision;
    3. failed to observe due care and precaution and to maintain proper and adequate control of the motor vehicle;
    4. failed to keep a proper lookout for other vehicles lawfully on the highway;
    5. failed to exercise reasonable care in the operation of the motor vehicle under the circumstances then and there existing; and
    6. In other respects not now known to the Plaintiff but which may become known before or at the time of trial.
  2. As a direct and proximate result of the negligence and carelessness of the Defendant, the Plaintiff:
    1. suffered serious, painful, and permanent bodily injuries, great physical pain and mental anguish, severe and substantial emotional distress, loss of the capacity for the enjoyment of life;
    2. was, is, and will be required to undergo medical treatment and incur medical costs and expenses to alleviate injuries, pain and suffering;
    3. was, is, and will be precluded from engaging in normal activities and pursuits, including a loss of ability to earn money and actual earnings;
    4. and, otherwise was hurt, injured, and caused to sustain losses.
  3. All of the Plaintiff’s losses were, are, and will be due to the carelessness and negligence of the Defendant, James C. Sexton, without any negligence or want of due care on the Plaintiff’s part contributing to the harm done.

WHEREFORE, this Plaintiff claims ONE MILLION FIVE HUNDRED THOUSAND DOLLARS ($1,500,000.00) in damages.

Respectfully submitted,
Miller & Zois, LLC

Ronald V. Miller
Miller & Zois, LLC
1 South Street, Suite 2450
Baltimore, MD 20201
(410) 779-4600
(410) 760-8922 (Fax)
Attorneys for Plaintiffs

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