What are common issues in a motor vehicle accident case?

As observed by Gerow J. in Reid v. Ford Motor Company, 2003 BCSC 1632 at para. 42, the courts have held that certain types of claims can raise common issues and have held as follows: 1. Claims sounding in negligence raise common issues because no class member can prevail without showing duty and breach; 2. A changing standard of care over time will not necessarily prevent certification in a negligence case – the court may answer the breach of standard differently for different time periods (and therefore class members) but they all share an interest in the answer to the question; and 3. Punitive damages are appropriately certified as common issues because the focus of the inquiry into the award is on the conduct of the defendant.