Question juridique clé
Whether the post-accident complaints remained in adequate causal connection to the accident under whiplash jurisprudence
Solution extraite
The accident was middle-range but not at the border of serious cases; only two criteria were met and none in particularly marked form, so adequate causation was denied.
Motifs extraits
The court applied the refined whiplash criteria of BGE 134 V 109, found no objectively proven organic injury, classified the accident as medium severity, and held that the combination of criteria was insufficient.