★ ATTORNEY REVIEWED. LEGAL ACCURACY VERIFIED
Reviewer: Steve Hayes, J.D. – Founder & Managing Attorney
NC Bar: #18224 | Focus: Independence Boulevard Accident Law, US-74 Crash Claims, Charlotte Surface Street Liability, Pedestrian Injury Claims
Founded: 1991 | Last Reviewed: March 2026 | Reviewed under N.C.G.S. § 20-141 (speed limits), N.C.G.S. § 20-155 (right of way), N.C.G.S. § 20-158 (traffic signals), N.C.G.S. § 1-139 (contributory negligence), and applicable NC motor vehicle law
Educational content only, not legal advice. Results vary by case.
Independence Boulevard Accident Lawyer Charlotte NC: US-74 Crash Claims, Dangerous Intersections, and NC Law
Reviewed by Steve Hayes, J.D., NC Bar #18224 | Last updated March 2026

Key Takeaways: Independence Boulevard Accident Lawyer Charlotte NC
- Independence Boulevard (US-74) is consistently Charlotte’s highest-crash surface street by CMPD annual report data – the combination of high posted speeds (up to 55 mph in some segments), continuous commercial driveway cuts, multiple dangerous intersections, and one of the highest pedestrian injury concentrations in Mecklenburg County makes Independence Boulevard a uniquely hazardous corridor that requires specific knowledge to litigate effectively.
- The Albemarle Road intersection is the most dangerous single location on Independence Boulevard – NCDOT’s High Accident Location data consistently lists the Independence Boulevard / Albemarle Road intersection among Charlotte’s highest crash-count intersections. If your accident occurred here, the documented history of crashes at this specific location supports your attorney’s case for intersection hazard contributing to the crash.
- Pedestrian and cyclist accidents on Independence Boulevard are disproportionately severe – the posted speed and traffic volume on US-74 mean that pedestrian impacts are rarely survivable. Multiple pedestrian fatalities per year along the Independence Boulevard corridor reflect inadequate pedestrian infrastructure – crossing distances, signal timing, and lighting – that in some cases create NCDOT or City of Charlotte liability above the at-fault driver’s responsibility.
- Commercial driveway cut accidents on Independence Boulevard create property owner and NCDOT liability dimensions – access points to shopping centers, gas stations, and commercial properties along US-74 create continuous merge-and-yield hazards where vehicles entering and exiting the driveway cross active travel lanes. A vehicle that failed to yield when entering Independence Boulevard from a commercial driveway has violated N.C.G.S. § 20-155 – and the property owner who designed or permitted inadequate sight distance at the access point may share liability.
- Speed limit transitions on Independence Boulevard are a specific contributory negligence risk – the posted speed on Independence Boulevard varies from 55 mph in the eastern sections to 45 mph and 35 mph in the western sections closer to Uptown. Drivers traveling at 55 mph in a 45 mph zone face a statutory violation argument from the defense. Your attorney establishes the specific posted limit at the exact accident location from NCDOT sign records.
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Independence Boulevard: Charlotte’s Highest-Crash Surface Street
Independence Boulevard – designated US Route 74 – runs roughly 13 miles from Uptown Charlotte eastward through East Charlotte, Albemarle Road, Idlewild Road, and Matthews toward Union County. It carries some of the highest traffic volumes of any non-interstate road in Mecklenburg County, operates at posted speeds up to 55 mph in its eastern sections, and lacks the grade-separation and access control that makes interstate travel comparatively safer. The result is a continuous mix of high-speed through traffic, commercial access movements, pedestrian crossings, and intersection conflicts that CMPD data consistently shows producing more crashes per mile than any other Charlotte surface street.
The structural factors that make Independence Boulevard uniquely dangerous as a surface street:
- High posted speed without grade separation: At 55 mph in its eastern sections, Independence Boulevard operates at interstate speeds but with intersection-controlled access – meaning vehicles at highway speed must yield, stop, and re-accelerate at signalized intersections in ways that freeway design eliminates entirely. The kinetic energy in a 55 mph crash is more than twice that of a 35 mph crash.
- Continuous commercial access density: The eastern Independence Boulevard corridor is among Charlotte’s most commercially dense surface street corridors – auto dealerships, shopping centers, restaurants, gas stations, and industrial properties with frequent driveway cut access points in both directions throughout the 13-mile route.
- Pedestrian demand without adequate infrastructure: East Charlotte neighborhoods that line Independence Boulevard have significant pedestrian populations – particularly near the Albemarle Road and Central Avenue intersections – but the street’s design reflects its highway-speed character rather than its pedestrian-heavy adjacent land use. Crossing distances, signal timing, and lighting conditions create pedestrian exposure that produces some of the highest pedestrian injury rates in Mecklenburg County.
- Multiple high-crash intersections: The concentration of signalized intersections on Independence Boulevard means the approach-and-stop vehicle conflict pattern that produces T-bone and rear-end crashes at signalized intersections is repeated continuously throughout the corridor’s length.
Most Dangerous Intersections and Segments on Independence Boulevard
NCDOT’s High Accident Location program and CMPD’s annual crash reporting identify specific Independence Boulevard intersections with disproportionate crash histories – documentation your attorney uses to establish the intersection’s known hazardous character when accidents occur at these locations.
Independence Blvd / Albemarle Road Intersection
Consistently listed among Charlotte’s most dangerous intersections by NCDOT and CMPD data. The convergence of US-74 through traffic with Albemarle Road cross-traffic creates T-bone and rear-end crash concentrations that have prompted multiple NCDOT safety studies. If your accident occurred here, the documented crash history is direct evidence of the intersection’s known hazardous character.
Independence Blvd / Central Avenue Interchange
The Central Avenue / East Independence interchange involves complex ramp geometry where drivers transitioning between Independence Boulevard and Central Avenue make merge decisions under high-speed pressure. The interchange’s design has been identified in NCDOT safety reviews as creating driver confusion – a road design defect argument when the confusion contributes to a crash.
Idlewild Road Section (East Charlotte)
The Idlewild Road area of Independence Boulevard combines a speed transition (from 55 mph to lower posted limits near Matthews), high commercial driveway density, and the beginning of the suburban-to-urban character change that creates speed limit compliance ambiguity. Rear-end crashes occur when lead vehicles slow for Idlewild Road traffic while following vehicles are traveling at 55 mph east-section speed.
Matthews / Stallings Approach (US-74 East)
As US-74 approaches Matthews and the Union County border, the character changes from urban arterial to suburban/semi-rural – but the speed remains high. Cross-county accident claims (Union County) require filing in Union County Superior Court in Monroe rather than Mecklenburg County. Charlotte NC Car Accident Lawyers Group handles US-74 claims throughout Union County.
Independence Blvd / Sharon Amity Road
The Sharon Amity Road intersection sits in a commercial corridor with high retail-destination traffic. Left-turn crash frequency is elevated at this location from vehicles turning across oncoming US-74 traffic from the median turn lane. Failure to yield on a left turn across high-speed traffic is one of the most predictable serious-injury crash mechanisms on the corridor.
Independence Blvd / Monroe Road / East Boulevard
Near the western end of Independence Boulevard approaching Uptown, the Monroe Road and East Boulevard intersections mark the transition to lower urban speeds. Crashes here involve both the high-speed through traffic from the eastern corridor and the pedestrian-intensive Dilworth/Elizabeth neighborhood land use on Independence Boulevard’s western end.
Pedestrian and Cyclist Accidents on Independence Boulevard
Independence Boulevard’s combination of high posted speeds, inadequate pedestrian crossing infrastructure, and pedestrian-heavy adjacent neighborhoods produces pedestrian injuries at rates that exceed virtually any other surface street in Mecklenburg County – and several of these cases involve not only driver negligence but NCDOT or City of Charlotte infrastructure liability.
The pedestrian liability analysis on Independence Boulevard involves multiple potential defendants:
- At-fault driver negligence: Under N.C.G.S. § 20-155 and § 20-158, drivers must yield to pedestrians in crosswalks and obey signal phases. A driver who struck a pedestrian in a marked crosswalk during a walk signal has violated both provisions – negligence per se.
- NCDOT pedestrian infrastructure liability: Where NCDOT’s design choices – crossing distance, signal timing, lighting specifications, or median refuge island placement – created conditions that made safe pedestrian crossing impractical or impossible, the infrastructure design is a road design defect claim under the NC Tort Claims Act. The 3-year limitations period for NC Tort Claims Act claims runs from the date of injury discovery, subject to specific notice requirements at the Industrial Commission.
- City of Charlotte signal timing liability: Charlotte’s traffic engineering department controls signal timing on US-74 within city limits. Signal timing that gives pedestrians an inadequate WALK phase for the crossing distance, or that creates conflicting vehicle movements during pedestrian phases, is a municipal engineering negligence claim subject to the City’s governmental immunity analysis. Where the City has purchased liability insurance, the immunity may be waived under N.C.G.S. § 160A-485.
Cyclist accidents on Independence Boulevard face a specific contributory negligence risk from the defense’s argument that cycling on a 55 mph arterial was itself negligent. Your attorney establishes through NC cycling law that cyclists have a statutory right to use the roadway under N.C.G.S. § 20-171.7 and that the driver’s violation of the 4-foot passing rule under N.C.G.S. § 20-149 is negligence per se independent of any route-choice argument.
Commercial Driveway Cut Accidents: Property Owner and NCDOT Access Permit Liability
The Independence Boulevard corridor’s high commercial driveway density creates a specific accident type that occurs nowhere else in the Charlotte crash data with the same frequency – vehicles entering or exiting commercial properties across active US-74 travel lanes, often with inadequate sight distance or yield compliance. These accidents have a potential liability track against the property owner and NCDOT above any driver negligence.
Commercial driveway cut accidents on Independence Boulevard create liability against:
- The vehicle operator: A driver exiting a commercial driveway onto Independence Boulevard failed to yield to US-74 through traffic under N.C.G.S. § 20-155. A driver entering a commercial driveway cut across oncoming lanes failed to yield to oncoming traffic. Both are statutory violations creating negligence per se.
- The property owner: A commercial property owner who designed, maintained, or permitted a driveway access point with inadequate sight distance – where the geometry of the driveway’s approach to US-74 physically prevents drivers from seeing oncoming traffic at adequate distances – may bear independent premises liability for creating a hazardous access point that foreseeably caused the type of accident that occurred.
- NCDOT access permit compliance: Commercial driveway access points onto state-maintained roads require NCDOT access permits specifying sight distance minimums, driveway geometry, and acceleration/deceleration lane requirements. A driveway that does not comply with its NCDOT access permit creates a government records-based liability argument against both the property owner (who failed to build or maintain per permit) and potentially NCDOT (which issued a permit for a hazardous access point).
Speed Limit Transitions and Contributory Negligence Exposure on Independence Boulevard
Independence Boulevard’s speed limit varies significantly along its length – from 55 mph in the eastern sections to 45 mph and 35 mph approaching Uptown. These transitions create specific contributory negligence defense arguments that depend on knowing the exact posted speed at the precise accident location.
The defense will argue that your speed was above the posted limit at the specific accident location if any evidence suggests speed above the current section’s posted limit. Establishing the exact posted speed at the accident location requires:
- NCDOT sign placement records: NCDOT maintains records of speed limit sign locations, change points, and post dates. The exact milepost of the last posted speed limit sign before the accident location determines the applicable limit.
- Accident scene photographs from immediately after the crash: Photographs of visible speed limit signs in the vicinity of the accident preserve the posted limit at the time of the crash – before any sign changes.
- ECM data from your vehicle: Your vehicle’s own event data recorder documents your pre-crash speed, which your attorney compares against the documented posted limit at the specific location to evaluate the contributory negligence exposure.
Charlotte NC Car Accident Lawyers Group builds the speed limit documentation for every Independence Boulevard case as part of the first-day evidence preservation protocol – before the insurer’s investigation establishes a competing narrative about your speed.
NC Statutes Applied to Independence Boulevard Accident Claims
Independence Boulevard accident claims involve the full range of NC surface street and intersection accident statutes – with the pedestrian, driveway cut, and signal-controlled intersection patterns predominating over the high-speed merge and following-too-closely patterns that dominate I-485 and I-85 claims.
Key NC statutes applied in Independence Boulevard accident cases:
- N.C.G.S. § 20-155 — Right of way: Controls failure to yield claims at driveways, unsignalized intersections, and pedestrian crosswalks. Violation is negligence per se for resulting injuries.
- N.C.G.S. § 20-158 — Traffic signals: Controls red-light violation claims. Running a red light on Independence Boulevard is negligence per se – the statutory violation establishes breach of duty without additional proof.
- N.C.G.S. § 20-141 — Speed limit: Posted speed varies from 35 to 55 mph by section. Violation at the specific posted limit at the accident location is negligence per se.
- N.C.G.S. § 20-149 — 4-foot passing rule: Drivers must leave at least 4 feet of clearance when passing cyclists. Violation in cyclist accident cases establishes negligence per se and can overcome insurance company arguments about cyclist route choice on a high-speed arterial.
- N.C.G.S. § 1-52 — Statute of limitations: Three years for personal injury. Two years for wrongful death. Intersection camera footage and business surveillance cameras along the corridor are overwritten on schedules much shorter than these deadlines.
Evidence in Independence Boulevard Accident Cases
Independence Boulevard accident cases have different evidence profiles than highway crash cases – more intersection camera footage opportunities, more business surveillance camera coverage, and more witness availability from nearby commercial properties, but fewer dedicated NCDOT ITS cameras than major interstate corridors.
Independence Boulevard accident evidence sources and their retention windows:
- Business surveillance cameras [24-72 hours to weeks]: The commercial corridor along Independence Boulevard means more privately-owned surveillance cameras than almost any other Charlotte road. Gas stations, convenience stores, auto dealerships, restaurants, and shopping centers along US-74 typically have exterior cameras covering the roadway. Your attorney sends preservation demands to all nearby businesses within 24 hours of retention.
- Traffic signal camera systems: Charlotte’s traffic signal management system includes cameras at many Independence Boulevard intersections used for signal timing and incident management. These cameras have varying retention periods – your attorney demands footage from the specific signal system at the accident intersection within 24 hours.
- NCDOT ITS cameras: Fewer fixed NCDOT ITS cameras cover Independence Boulevard than interstate corridors, but cameras at the major interchange points (Central Avenue, Albemarle Road) may have footage of the accident or vehicles involved in the accident approaching the location.
- Police in-car and body cameras: CMPD units responding to Independence Boulevard accidents often have dash and body cameras. CMPD camera footage retention is typically 90 days but can be extended with a preservation demand.
- Vehicle EDR data: Both vehicles’ event data recorders document pre-crash speed and braking in the 5 seconds before impact. This data is preserved by demanding that neither vehicle be repaired until an expert can download the EDR data.
Frequently Asked Questions: Independence Boulevard Accident Lawyer Charlotte NC

Why is Independence Boulevard so dangerous in Charlotte?
Independence Boulevard (US-74) operates at posted speeds up to 55 mph with continuous intersection-controlled access, commercial driveway cuts in both directions, high pedestrian demand from adjacent East Charlotte neighborhoods, and multiple signalized intersections where high-speed through traffic conflicts with turning and crossing vehicles. CMPD annual data consistently shows US-74 as Charlotte’s highest-crash surface street per mile.
What is the most dangerous intersection on Independence Boulevard?
The Independence Boulevard / Albemarle Road intersection is consistently listed among Charlotte’s highest crash-count intersections by NCDOT and CMPD data. If your accident occurred at or near this intersection, the documented crash history at this specific location is direct evidence of its known hazardous character – supporting your claim that the intersection’s design contributed to the conditions that allowed the crash to occur.
Can I sue if a car pulled out of a driveway and hit me on Independence Boulevard?
Yes. A driver exiting a commercial driveway onto US-74 must yield to through traffic under N.C.G.S. Section 20-155. Failure to yield is negligence per se. Depending on the specific driveway’s access design, the property owner may also bear liability if inadequate sight distance or non-compliant driveway geometry contributed to the crash. Your attorney investigates the driveway’s NCDOT access permit compliance as part of the first-week evidence gathering.
Who is liable if a pedestrian is hit on Independence Boulevard?
Potentially multiple parties: the driver (for failing to yield under N.C.G.S. Section 20-155 or running a red light under Section 20-158); NCDOT (if the pedestrian crossing infrastructure – distance, signal timing, lighting – was inadequate under the NC Tort Claims Act); and the City of Charlotte (if signal timing that provided inadequate pedestrian crossing time contributed to the accident, subject to governmental immunity analysis). Charlotte NC Car Accident Lawyers Group investigates all three tracks simultaneously.
What is the speed limit on Independence Boulevard?
It varies by section: 55 mph in the eastern sections (east of Albemarle Road toward Matthews), transitioning to 45 mph in middle sections, and lower in the western sections approaching Uptown Charlotte. The exact posted speed at the specific accident location is established from NCDOT sign records and accident scene photographs. The speed limit at your precise location determines the contributory negligence exposure if the defense argues you were speeding.
Does NC contributory negligence apply to Independence Boulevard accidents?
Yes – under N.C.G.S. Section 1-139, any fault on your part bars all recovery against the at-fault driver. Common Independence Boulevard contributory negligence arguments include: speed above the posted limit in the applicable section; failure to observe a traffic signal; failure to yield at an intersection. Your attorney counters all three with intersection camera footage, business surveillance video, and vehicle EDR data before the insurer’s investigation is complete.
Can a cyclist sue after being hit on Independence Boulevard?
Yes. NC cycling law under N.C.G.S. Section 20-171.7 gives cyclists the same right to use the roadway as motor vehicles. A driver who passed you with less than 4 feet of clearance violated N.C.G.S. Section 20-149’s 4-foot passing rule – negligence per se, independent of any argument about whether cycling on a 55 mph road was wise. The defense will argue contributory negligence from route choice; your attorney counters with the statutory right to use the roadway and the driver’s independent violation.
What if the Independence Boulevard accident happened in Matthews or Union County?
US-74 continues from Charlotte through Matthews and into Union County. Accidents in Matthews fall in Mecklenburg County (Matthews is within Mecklenburg). Accidents in Stallings or Indian Trail fall in Union County Superior Court in Monroe. The applicable NC law is the same, but the venue is different. Charlotte NC Car Accident Lawyers Group handles US-74 cases throughout Union County.
How long do I have to file an Independence Boulevard accident lawsuit?
Three years under N.C.G.S. Section 1-52 for personal injury. Two years for wrongful death under N.C.G.S. Section 28A-18-2. Business surveillance camera footage along Independence Boulevard typically retains for 7-30 days before overwrite – far shorter than the limitations deadline. Retain an attorney within days of the crash to preserve this footage before it is gone.
What if a business’s poor driveway design contributed to my Independence Boulevard accident?
A commercial property owner whose driveway access point has inadequate sight distance – where the approach geometry physically prevents drivers from seeing oncoming US-74 traffic before entering the travel lane – may bear premises liability for creating a foreseeable hazard. Your attorney documents the driveway geometry, the sight distance from the driveway approach to the travel lane, and the NCDOT access permit requirements for the specific access point.
Can I sue NCDOT for a bad road design on Independence Boulevard?
Yes, through the NC Tort Claims Act at the NC Industrial Commission. NCDOT road design claims on Independence Boulevard most commonly involve: inadequate pedestrian crossing infrastructure; access point geometry that creates sight distance deficiencies; signal timing that fails to provide adequate pedestrian crossing time; and construction zone design deficiencies. The NC Tort Claims Act claim has different pleading requirements and procedural rules from standard civil litigation – it must be filed at the Industrial Commission, not in superior court.
What evidence is most important in an Independence Boulevard accident case?
Business surveillance camera footage from nearby commercial properties (24-72 hour overwrite window); traffic signal camera footage from the accident intersection; CMPD in-car and body camera footage; vehicle EDR data from both vehicles; witness accounts from nearby commercial property employees; and NCDOT sign records establishing the posted speed at the specific accident location.
What if I was rear-ended while stopped for a red light on Independence Boulevard?
A driver who rear-ended you while you were stopped at a red light is liable under N.C.G.S. Section 20-152 (following too closely) for failing to maintain adequate stopping distance. The defense will examine whether you stopped suddenly or had non-functioning brake lights – claims your attorney counters with traffic signal camera footage showing the signal state and police report documentation of brake light function. This is one of the strongest liability cases in the Charlotte accident system.
What if the driver who hit me on Independence Boulevard ran a red light?
A red light violation under N.C.G.S. Section 20-158 is negligence per se – the statutory violation establishes the breach of duty as a matter of law. The remaining analysis is causation and damages. Traffic signal camera footage is the most powerful evidence of a red light violation. This footage must be preserved within 24-72 hours of the accident. Charlotte NC Car Accident Lawyers Group issues preservation demands to the Charlotte traffic signal management system within 24 hours of every case retention.
Are hit-and-run accidents common on Independence Boulevard?
Hit-and-run crashes occur on Independence Boulevard at rates reflecting its high traffic volume. When the at-fault driver cannot be identified, your own uninsured motorist coverage under N.C.G.S. Section 20-279.21 is the primary recovery path. Business surveillance cameras along the commercial corridor are your best chance of capturing the at-fault vehicle’s license plate – another reason the 24-hour preservation demand to nearby businesses is urgent in Independence Boulevard hit-and-run cases.
What if my Independence Boulevard accident happened during construction?
Active construction on US-74 creates the same multi-defendant framework as I-85 and I-485 construction zone accidents – driver negligence, NCDOT contractor liability, and traffic control subcontractor liability all potentially available. Construction zone speed limits (typically 55 mph reduced to 45 or lower) create a specific statutory violation argument when the at-fault driver was speeding in the posted zone.
Does Charlotte NC Car Accident Lawyers Group handle accidents on the full US-74 corridor?
Yes, from the western Independence Boulevard approach near Uptown Charlotte through East Charlotte, Matthews, Stallings, Indian Trail, and into Union County along US-74. Steve Hayes has represented US-74 corridor accident victims since 1991. We handle cases in both Mecklenburg and Union county courts. No fee unless compensation is recovered. Call (980) 239-2275.
How does Charlotte NC Car Accident Lawyers Group handle Independence Boulevard accident cases?
Charlotte NC Car Accident Lawyers Group immediately sends preservation demands to all nearby businesses with surveillance cameras, the traffic signal management system, and CMPD; documents the exact posted speed at the accident location from NCDOT sign records; retrieves vehicle EDR data before either vehicle is repaired; and builds the contributory negligence counter-analysis from intersection camera and business surveillance footage before the insurer’s investigation is complete. Steve Hayes analyzes all liability tracks – driver negligence, property owner liability, and NCDOT infrastructure claims – simultaneously from the first consultation. No fee unless we win. Call (980) 239-2275.
Related Independence Boulevard Accident Resources
- Charlotte Car Accident Lawyer
- Charlotte I-485 Accident Lawyers
- Charlotte I-77 Accident Lawyers
- Charlotte Truck Accident Lawyers
- Charlotte Head-On Collision Lawyers
- Charlotte Rear-End Collision Lawyers
- Charlotte Distracted Driving Accident Lawyers
- Charlotte Drunk Driving Accident Lawyers
- Charlotte Wrongful Death Lawyers
- Charlotte Catastrophic Injury Lawyers
- Can I Sue If Partially at Fault in NC?
Your Charlotte Independence Boulevard Accident Lawyers

Steve Hayes, J.D. – Founder & Managing Attorney
Steve Hayes has represented personal injury clients in Charlotte since 1991, including US-74 Independence Boulevard accident cases involving intersection liability, commercial driveway cut claims, pedestrian injuries, and NCDOT road design defect claims throughout Mecklenburg and Union counties.
Bar: NC (#18224) | SC | Education: UNC Greensboro, B.A. | Campbell University School of Law, J.D.

Cameron Bauer, Esq. – Associate Attorney
Cameron Bauer works alongside Steve Hayes on North Carolina personal injury cases including Independence Boulevard accident claims, pursuing driver negligence, property owner liability, and NCDOT infrastructure claims simultaneously.
Bar: NC (#63306) | Education: University of South Carolina, B.A. | Elon University School of Law, J.D.
Authoritative Sources
- N.C.G.S. § 20-141 – Speed Limits
- N.C.G.S. § 20-152 – Following Too Closely
- N.C.G.S. § 20-154 – Unsafe Lane Change
- N.C.G.S. § 20-155 – Right of Way
- N.C.G.S. § 20-158 – Traffic Signals and Signs
- N.C.G.S. § 1-139 – Contributory Negligence
- N.C.G.S. § 1-52 – Statute of Limitations
- N.C.G.S. § 28A-18-2 – Wrongful Death
- NC Department of Transportation
- North Carolina State Bar
7421 Carmel Executive Park Drive, Suite 212, Charlotte, NC 28226 | (980) 239-2275
Disclaimer: Educational purposes only. Not legal advice. No attorney-client relationship formed. Independence Boulevard Accident cases are complex and fact-specific – outcomes depend on the unique circumstances of each case. Past results do not guarantee future outcomes.
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