7 Jury Instruction A following motorist who rear ends the vehicle in front of him is presumed to breach the standard of care set forth in La. R.S. § 32:81. To avoid liability, the burden of proof is on the rear- ending motorist to show that he kept his vehicle under control, watched the vehicle in front of him closely, and kept a safe distance, or that the lead driver created a hazard which he could not reasonably avoid.
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