Abrams v. City of Chicago
211 Ill. 2d 251, 811 N.E.2d 670, 285 Ill. Dec. 183 (2004)
Rule of Law:
A defendant's conduct is not the legal cause of an injury if it does nothing more than furnish a condition by which the injury is made possible by the subsequent, independent, and unforeseeable criminal or reckless acts of a third party.
Facts:
- Patricia Abrams, who was in labor with contractions ten minutes apart, called 911 requesting an ambulance to take her to the hospital.
- The 911 dispatcher told Abrams it was not an emergency and hung up; a second call from Abrams' sister resulted in the dispatcher providing the number for a private ambulance service.
- The private ambulance service informed Abrams' sister that they did not have an ambulance available.
- Abrams' friend, Henrietta Young, then drove Abrams toward the hospital.
- While en route, Young drove through a red light at an intersection.
- Young's vehicle was struck by a car driven by Gregory Jones, who was speeding at 75-80 miles per hour.
- Jones later admitted to police that he had consumed alcohol and crack cocaine before the accident and was driving on a suspended license.
Procedural Posture:
- Patricia Abrams sued the City of Chicago in the trial court for negligence.
- The City of Chicago filed a motion for summary judgment, arguing it had no duty and its actions were not the proximate cause of the injury.
- The trial court granted the City's motion for summary judgment, finding a lack of proximate cause.
- Abrams, as the appellant, appealed the decision to the intermediate appellate court.
- The appellate court reversed the trial court's judgment.
- The City of Chicago, as the appellant, petitioned the Supreme Court of Illinois for leave to appeal, which the court granted.
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Issue:
Is a city's refusal to dispatch an ambulance for what it deems a non-emergency the legal cause of injuries sustained in an automobile accident, when the accident is immediately caused by the illegal acts of two separate drivers?
Opinions:
Majority - Justice Thomas
No. The city's refusal to dispatch an ambulance was not the legal cause of the injuries sustained in the subsequent automobile accident. To establish proximate cause, a plaintiff must prove both cause in fact and legal cause. While the city's refusal may have been a 'cause in fact' (i.e., but for the refusal, Abrams would not have been in her friend's car), it was not the 'legal cause.' Legal cause is a question of foreseeability, asking whether the injury is of a type that a reasonable person would see as a likely result of their conduct. Here, the court found it was not reasonably foreseeable that refusing an ambulance for a woman with labor pains ten minutes apart would result in her driver running a red light simultaneously with a substance-impaired, speeding driver illegally entering the same intersection. The illegal acts of Young and Jones were independent, intervening causes that broke the chain of causation, rendering the City's conduct merely a 'condition' that made the injury possible, not its legal cause.
Analysis:
This decision reinforces the critical distinction between 'cause in fact' and 'legal cause' in negligence law, particularly in cases involving intervening third-party acts. It establishes a high bar for foreseeability, shielding defendants, especially municipalities, from liability when their conduct creates a condition for harm, but the direct cause is the unforeseeable and illegal behavior of others. The 'condition versus cause' analysis provides a robust defense, requiring future plaintiffs to demonstrate that the intervening illegal acts were a probable and likely consequence of the defendant's original negligence, not just a remote possibility. This solidifies the principle that one is generally not liable for the criminal or reckless acts of third parties that one did not cause or could not reasonably anticipate.
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