Chacko v. Com., Dept. of Transp.
611 A.2d 1346, 148 Pa. Commw. 494, 1992 Pa. Commw. LEXIS 438 (1992)
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Rule of Law:
An actor's antecedent negligence is not the proximate cause of an injury if a subsequent, unforeseeable event, which is extraordinary in nature and operates independently of the actor's negligence, intervenes and becomes a superseding cause of the harm. Furthermore, a municipality has no general common law or statutory duty to erect traffic signs or to enforce its own ordinances against third parties.
Facts:
- Ruby Matthews, who suffers from diabetes, was driving a car with Saramma Chacko and Celinamma John as passengers in the City of Philadelphia.
- While driving, Matthews lost consciousness and subsequently lost control of the vehicle.
- The vehicle left the roadway and struck a utility pole.
- The utility pole was owned by the Philadelphia Electric Company (PECO) and was located 14 inches from the roadway.
- This placement was one inch closer to the street than permitted by a City ordinance, and PECO had not received approval for the deviation.
Procedural Posture:
- Saramma Chacko and Celinamma John sued the City of Philadelphia, Ruby Matthews, and Philadelphia Electric Company in the Court of Common Pleas of Philadelphia County, a trial court.
- The City of Philadelphia filed a motion for summary judgment.
- The trial court granted the City's motion for summary judgment, dismissing the claims against it.
- Chacko and John, as Appellants, appealed the grant of summary judgment to the Commonwealth Court of Pennsylvania.
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Issue:
Does a driver's sudden and unforeseeable loss of consciousness constitute a superseding cause that absolves a municipality from liability for its alleged antecedent negligence in road design, sign placement, and ordinance enforcement?
Opinions:
Majority - Lederer, Senior Judge
Yes. A driver's sudden loss of consciousness is an extraordinary and unforeseeable event that acts as a superseding cause, breaking the chain of legal causation and relieving the city of liability for any alleged prior negligence. The court reasoned that to hold the City liable, its actions must be a legal cause of the injuries. However, the driver's medical emergency was an intervening force. Citing the Restatement (Second) of Torts, the court applied a foreseeability test, stating that an intervening act becomes a superseding cause if, viewed retrospectively, it is 'so extraordinary as not to have been reasonably foreseeable.' The court concluded that Matthews's loss of consciousness was such an event, as it operated independently of any situation created by the City's alleged negligence (e.g., road design or pole placement) and was not a normal result of that situation. Additionally, the court affirmed that the City had no duty to erect traffic signs or enforce its own ordinances against PECO, providing independent grounds for dismissing those specific claims.
Analysis:
This decision reinforces the doctrine of superseding cause as a complete defense in negligence actions, particularly for government defendants. It clarifies that even if a plaintiff can establish duty and breach, a sufficiently 'extraordinary' and 'unforeseeable' intervening act by a third party will sever legal causation and absolve the original actor of liability. The case provides a clear example of how a third party's unforeseeable medical emergency can shield a municipality from liability for potentially dangerous conditions on its property. This holding emphasizes the critical distinction between conditions that merely 'facilitate' an injury and the direct, legal cause of the harm.
