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It would depend upon the circumstances. If the passenger is a fully functioning adult, then yes, it would likely be the passenger's fault. If, however, the passenger was under the charge of the adult driver (such as a young child, or an adult with diminished mental capacity), then it could be argued that the driver created the circumstances in which the crash was liable to occur by placing the passenger in the front seat, and the driver could therefore be found to be at least partially At Fault.

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Q: Is the passenger at fault when they grab the steering wheel and cause a car to lose control and crash?
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