Watson v. Kentucky & Indiana Bridge & Railroad Company

Kentucky Court of Appeals · 1910 · Torts

126 S.W. 146 (Ky. 1910)

Updated July 23, 2026

TortsNegligenceProximate CauseIntervening Causeforeseeabilitysuperseding causegasoline explosionrailroad negligence

Facts

A tank car loaded with gasoline and owned by Union Tank Line Company was being hauled through Louisville by Kentucky & Indiana Bridge & Railroad Company when it derailed, breaking the discharge pipe and valve appliances and allowing gasoline to escape for hours. Evidence for Watson tended to show the derailment resulted from defective track and that the railroad's employees may also have mishandled the tank and failed adequately to warn nearby residents. Gas spread through the surrounding area, and about three hours later Charles Duerr struck a match on Madison Street, causing an explosion that injured Watson in his home. There was conflicting evidence on whether Duerr acted innocently or negligently in lighting the match, or maliciously and for the purpose of causing the explosion.

Issue

Whether the trial court erred in directing a verdict for the Bridge & Railroad Company and the Union Tank Line Company. More specifically, whether Duerr's lighting and throwing of the match was necessarily the proximate cause of Watson's injuries as a matter of law, or whether proximate cause and intervening causation should have gone to the jury.

Rule

What is the proximate cause of an injury is ordinarily a question for the jury. An intervening act does not relieve a negligent defendant of liability if the intervening act was set in motion by the defendant's earlier negligence, was naturally induced by it, or was of a kind that reasonably should have been anticipated; when two causes concur to produce an injury, and the defendant is responsible for one of them, the defendant remains liable. But if the intervening act is so unexpected or extraordinary that it could not reasonably have been anticipated—such as a malicious or wanton act done for the purpose of causing the harm—that act becomes the efficient or proximate cause and breaks the chain of liability.

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

In Cincinnati, Iron Gate Freight Lines negligently ruptured a tanker during switching operations, releasing chemical vapors across a downtown block for hours. Unaware of the vapor cloud, Nora Ellis stepped outside a restaurant, struck a match to light a cigarette, and an explosion injured Leo Martin inside a nearby apartment.

If Leo sues Iron Gate Freight Lines, which is the best argument against the company’s motion for a directed verdict on proximate cause?

Explanation. The majority opinion states that proximate cause is ordinarily for the jury, and that an intervening act does not relieve the original negligent actor if the intervening act was naturally induced by the negligence or was reasonably to be anticipated. Ignition of escaped combustible vapor by someone striking a match for an ordinary purpose is the sort of contributing cause that does not necessarily break the chain.