Addis v. Steele

Massachusetts Appeals Court · Torts

TortsNegligencePremises liabilityInnkeeper dutyForeseeabilityIntervening criminal actsLandlord liabilityCorporate officer liability

Facts

The plaintiffs were paying guests at the Red Inn when an arsonist started a fire during the night. Awakened by the alarm, they encountered darkness, smoke, a fire in the dining room, and a locked door when attempting to escape; after other first-floor escape efforts failed, they returned upstairs, forced open a second-story window, jumped, and were injured. The trial judge found negligence in failing to have someone on duty at night, failing to provide sufficient or emergency lighting, and failing to provide accessible, properly marked, easily opened exits. The inn was operated by Tamerlane Corp., while the trust owned the building and had leased it to the corporation, which remained in exclusive possession and control as a tenant at will on the lease terms.

Issue

Whether the corporation could be liable for the plaintiffs' injuries despite the fire having been intentionally set by an arsonist, and whether the trust and individual defendants could also be held liable. More specifically, the case asked whether the criminal act was a superseding cause and whether the evidence supported liability against parties other than the corporate operator.

Rule

An innkeeper, though not an insurer of guest safety, owes guests a duty to take reasonable steps to protect them from unreasonable risks of physical harm, and that duty extends to foreseeable risks arising from third-party acts, including criminal acts. Where inadequate lighting and egress make injury from fire foreseeable, the fact that the fire was set by an arsonist does not as a matter of law relieve the innkeeper of liability. A landlord lacking possession and control over leased areas is liable only where it retained relevant control or negligently made contracted-for repairs, and corporate officers or agents are personally liable only for torts in which they personally participated, not for mere nonfeasance.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Lakeshore House, a small inn in Duluth, leaves its upstairs hallway without emergency lighting and keeps the rear exit chained after midnight so staff can "monitor traffic." A trespasser intentionally sets a trash-can fire in the lobby, and a guest breaks an ankle while trying to escape through smoke and darkness.

If the guest sues the inn operator for negligence, what is the strongest argument for imposing liability?

Explanation. An innkeeper is not an insurer, but it owes paying guests a duty to take reasonable steps to protect them from unreasonable risks of physical harm. Under the majority opinion, when deficient lighting and egress create a foreseeable risk of injury from fire, the fact that the fire was intentionally set does not break causation as a matter of law. Liability does not require strict liability or foresight of the exact wrongdoer or exact method. (Derived from Addis v. Steele (n.d.).)