Edwards v. Honeywell
50 F.3d 484 (1995)
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Rule of Law:
An alarm monitoring company owes no duty of care to a firefighter who is injured or killed responding to a fire, even if the company's negligence in relaying the alarm caused a delay in the response.
Facts:
- In 1982, Honeywell contracted with a couple named Baker to install and monitor a fire alarm system in their home.
- On an afternoon in 1988, a fire broke out in the furnace room of the Bakers' house.
- Mrs. Baker activated the fire and police buttons on the Honeywell alarm system control panel.
- Honeywell's alarm monitor received the signal but, due to outdated information, called the wrong fire department.
- This error caused a delay of approximately three minutes and fifteen seconds before the correct fire department, Lawrence Township, was notified.
- Firefighter David John Edwards entered the burning home as part of the response team.
- While Edwards was inside, the floor collapsed, causing him to fall into the basement where he was asphyxiated and died.
Procedural Posture:
- The widow of David John Edwards sued Honeywell in an Indiana state court for negligence.
- Honeywell had the case removed to the U.S. District Court for the Southern District of Indiana on the basis of diversity jurisdiction.
- The district court granted summary judgment in favor of Honeywell, ruling that it owed no duty of care to fireman Edwards.
- The plaintiff, Edwards' widow, appealed the district court's judgment to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Does an alarm company that negligently delays notifying the correct fire department of a fire owe a duty of care to a firefighter who is subsequently killed while fighting that fire?
Opinions:
Majority - Posner, Chief Judge
No. An alarm company that negligently delays notifying the correct fire department does not owe a duty of care to a firefighter killed in the subsequent blaze. The concept of duty in tort law serves as a judicial limitation on the scope of liability for negligence. Drawing on the principles of Palsgraf, which limits liability to foreseeable victims, and cases like Moch v. Rensselaer Water Co., which limit the liability of public-utility-type services to avoid crushing and indeterminate liability, the court found the firefighter was an unforeseeable victim in a practical sense. An alarm company has no knowledge of the specific risks of a fire on a subscriber's premises, no control over the firefighting techniques employed, and no ability to influence the training or leadership of a fire department. Imposing a duty would make the company an insurer for a range of harms it cannot reasonably calculate or control, and would provide only a marginal contribution to fire safety outweighed by the administrative costs and legal uncertainty.
Analysis:
This decision solidifies the judicial power to use the concept of 'duty' as a public policy tool to limit the scope of negligence liability, even when carelessness and causation are assumed. It extends the reasoning from classic foreseeability cases like Palsgraf to modern service providers, shielding them from liability to third parties where the chain of events is attenuated and the potential harm is practically unforeseeable. The court emphasizes a practical definition of foreseeability, focusing on whether a defendant can reasonably calculate, control, and insure against a particular risk. This ruling makes it more difficult for third-party emergency responders to sue ancillary service providers whose negligence contributes to, but does not directly create, the danger they face.
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