Pittway Corp. v. Collins

Court of Appeals of Maryland · Torts

Tortsproximate causesuperseding causeproducts liabilityfailure to warnproximate causelegal causecause in fact

Facts

Ryland built the house in 1989 and installed an AC-powered smoke detector without a battery backup; Pittway was among the manufacturer defendants. Years later, the basement was being used as sleeping space, and during an area-wide power outage children sleeping there used candles for light; a candle left burning caused a fire. Because the smoke detector lacked backup power, it did not sound during the outage. Two overnight child guests died and Chapman children were seriously injured, and the complaint alleged that the lack of warning and the failure to provide or convey information about the detector's limitations deprived the children of a reasonable opportunity to escape.

Issue

Whether, on the allegations of the complaint alone, intervening negligent acts by others superseded as a matter of law any negligence by Pittway and Ryland, so that the claims against them could properly be dismissed. More specifically, the question was whether foreseeability and superseding causation were conclusively resolved at the motion-to-dismiss stage.

Rule

Negligence is actionable only if it is both a cause in fact and a legally cognizable cause. Where multiple negligent acts contribute to an injury, Maryland uses the substantial-factor framework and assesses legal cause through foreseeability of both the harm and intervening acts; an intervening negligent act is superseding only when it is unusual, extraordinary, and not reasonably foreseeable under Restatement factors. Proximate cause is ordinarily for the trier of fact, and on a motion to dismiss superseding causation may be decided as a matter of law only when the facts alleged admit of but one inference and reasoning minds cannot differ.

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

In Columbus, Ohio, Nora Vega sued Lakefront Safety Devices, alleging its carbon-monoxide alarm was sold without a battery backup and without adequate warning that it would not function during a blackout. During a winter power outage, Nora's cousin used a gasoline heater indoors despite several adults noticing the fumes, and Nora was injured before anyone evacuated.

Lakefront moves to dismiss, arguing the adults' negligent use of the heater was a superseding cause as a matter of law. How should the court rule?

Explanation. Under the majority rule, proximate cause and superseding cause ordinarily are for the trier of fact. On a motion to dismiss, the court may resolve superseding causation as a matter of law only when the pleaded facts admit of but one inference and reasonable minds could not differ. A third party's negligence is superseding only when it is unusual, extraordinary, and not reasonably foreseeable; here the allegations permit competing inferences, so dismissal is premature. (Derived from Pittway Corp. v. Collins (n.d.).)