Giles v. City of New Haven
636 A.2d 1335, 228 Conn. 441 (1994)
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Rule of Law:
The doctrine of res ipsa loquitur may apply to infer a defendant's negligence even if the plaintiff was using the instrumentality at the time of injury, as exclusive control is not required, only that the defendant's negligence is the most plausible explanation. Furthermore, under a comparative negligence system, a plaintiff's potential contributory negligence does not bar the application of the doctrine but instead serves to reduce damages.
Facts:
- For fourteen years, the plaintiff was an elevator operator in the Powell Building in New Haven.
- The defendant, Otis Elevator Company, had a long-standing exclusive contract with the building owner to maintain and inspect the elevator and its component parts.
- While the plaintiff was operating the elevator, its compensation chain became hooked on a rail bracket in the elevator shaft.
- The plaintiff was unable to control the movement of the chain from inside the elevator cab.
- The chain tightened and then broke free from the two bolts securing it to the underside of the cab, causing the cab to shudder violently and injure the plaintiff.
- After the chain broke, it fell to the bottom of the shaft with a loud crash.
- Fearing for her safety, the plaintiff reversed the elevator to the nearest floor and jumped out, sustaining additional injuries.
- The defendant's maintenance supervisor testified that the compensation chain was not part of the routine inspection, and the bolts holding it had never been changed in the sixty-one years since the elevator's installation.
Procedural Posture:
- The plaintiff sued the defendant, Otis Elevator Company, in the trial court for personal injuries.
- At the conclusion of the plaintiff's case at trial, the defendant moved for a directed verdict.
- The trial court granted the defendant's motion for a directed verdict.
- The plaintiff appealed to the Appellate Court.
- The Appellate Court reversed the trial court's judgment, holding that the case should have been submitted to the jury under the doctrine of res ipsa loquitur.
- The defendant appealed the Appellate Court's decision to the Supreme Court of Connecticut.
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Issue:
Does the doctrine of res ipsa loquitur apply to allow a jury to infer negligence on the part of an elevator maintenance company when the elevator operator was using the elevator at the time of the accident, and can the doctrine apply in a jurisdiction with a comparative negligence statute?
Opinions:
Majority - Katz, J.
Yes, the doctrine of res ipsa loquitur applies. The doctrine allows an inference of negligence even if a defendant's control over the instrumentality was not exclusive, and it is compatible with a comparative negligence system. The court reasoned that the 'control' element of res ipsa loquitur is flexible and does not require absolute exclusivity. The critical inquiry is not whether the defendant's control was exclusive, but whether the defendant was responsible for the injury, meaning the defendant's negligence is the most plausible explanation. Here, the defendant had an exclusive contract to maintain the elevator parts that malfunctioned, which a jury could find was sufficient to infer the defendant was more likely responsible than someone else. The court also held that the advent of comparative negligence modifies the third element of the doctrine. A plaintiff no longer needs to prove they were completely free of fault; any negligence on the plaintiff's part will be compared with the defendant's and will reduce, rather than bar, recovery.
Analysis:
This case significantly modernizes the application of res ipsa loquitur in Connecticut by relaxing the traditional 'exclusive control' requirement and formally integrating the doctrine with comparative negligence principles. By shifting the focus from 'exclusive' control to whether the defendant is the 'most plausible' negligent party, the court makes it easier for plaintiffs to reach a jury in complex situations where multiple parties interact with an instrumentality. The adaptation to comparative negligence prevents the doctrine from being unfairly nullified by any minor fault of the plaintiff, aligning this evidentiary rule with the state's broader tort policy of apportioning, rather than barring, liability.
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