Heeter v. Honeywell International, Inc.
195 F. Supp. 3d 753, 2016 U.S. Dist. LEXIS 86181, 2016 WL 3577594 (2016)
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Rule of Law:
Under Pennsylvania law, a defendant's conduct or product failure is not the proximate cause of a plaintiff's harm when independent, intentional criminal acts by a third party, coupled with a significant lapse of time and distance, constitute superseding factors that break the chain of causation.
Facts:
- On October 11, 2014, an ADT sales representative met with Julie Heeter and Robert Heeter at their weekend residence in Benton, Pennsylvania, where Julie expressed concern about keeping specific individuals, including Cea Jay Chattin, off her property and wanted an alert system for intrusions.
- On November 8, 2014, ADT installed the “ADT Pulse” alarm system, which included a control panel manufactured by Honeywell, at the Heeters' residence.
- On March 26, 2015, at approximately 7:00 a.m., while the Heeters were not at their residence, Cea Jay Chattin entered through a window, disconnected the alarm system's phone lines, removed its control panel, and stole a .30 caliber rifle.
- The alarm system failed to notify Julie Heeter or the police of the intrusion or the disconnected phone lines.
- Cea Jay Chattin then traveled approximately twenty minutes to Bryan Harris’s apartment, where he waited for Harris to return from work.
- Around 8:00 p.m. that same evening, Bryan Harris returned to his apartment and had a conversation with Chattin outside.
- Later that evening, approximately fifteen hours after the break-in at the Heeters' residence, Chattin entered Harris’s apartment and fatally shot Harris in the face with the stolen .30 caliber rifle.
Procedural Posture:
- Plaintiff Julie Heeter initiated this action in the U.S. District Court for the Eastern District of Pennsylvania on February 3, 2016, asserting claims for fraud (against ADT), product liability for defective design (against both ADT and Honeywell), negligence (against both, though later withdrawn against Honeywell), wrongful death (against both), survival act (against both), and a Pennsylvania Unfair Trade Practices and Consumer Protection Law (UTPCPL) claim (against ADT).
- Plaintiff later moved for and was granted leave to file an Amended Complaint in the U.S. District Court for the Eastern District of Pennsylvania.
- Defendant Honeywell International, Inc. filed a motion to dismiss Plaintiff's Amended Complaint in the U.S. District Court for the Eastern District of Pennsylvania.
- Defendant ADT, LLC filed a motion for judgment on the pleadings regarding Plaintiff's Amended Complaint in the U.S. District Court for the Eastern District of Pennsylvania.
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Issue:
Does the failure of a home alarm system to notify a homeowner of an intrusion constitute the proximate cause of a murder committed fifteen hours later, several miles away, using a weapon stolen during that intrusion, when significant independent actions by the perpetrator intervened?
Opinions:
Majority - Eduardo C. Robreno, District Judge
No. The failure of the alarm system was not the proximate cause of Bryan Harris's death because the direct and intentional criminal acts of the perpetrator, separated by a significant lapse of time and distance, constituted superseding factors that broke the chain of causation. The court applied Pennsylvania's 'substantial factor' test for proximate causation, derived from the Restatement (Second) of Torts § 433, considering three factors: (1) the number and extent of other contributing factors; (2) whether the defendant's conduct created a continuous force or merely a harmless situation acted upon by other forces; and (3) the lapse of time. First, the court found that Chattin's premeditated decisions to steal the rifle, travel to Harris's apartment, wait, and murder him were substantially greater contributing factors than the alarm system's failure, citing Brown v. Phila. Coll. of Osteopathic Med.. Second, the court reasoned that the alarm system's failure did not initiate a continuously operating force but merely created a situation harmless unless acted upon by Chattin's independent criminal acts, for which Defendants were not responsible, drawing parallels to Mack v. AAA Mid-Atlantic, Inc. and Eckroth v. Pennsylvania Electric, Inc.. Third, the fifteen-hour lapse between the alarm failure and the murder, coupled with Chattin's intervening actions, further attenuated the causal connection, similar to the reasoning in Phillips v. Northwest Regional Communications. The court concluded that, as a matter of law, the alarm system's failure was not a substantial factor in producing Harris's death, and thus dismissed all claims with prejudice, deeming further amendment futile.
Analysis:
This case strongly emphasizes the high bar for establishing proximate causation under Pennsylvania law, particularly when an independent, intentional criminal act by a third party intervenes. It demonstrates that courts will determine proximate cause as a matter of law if no reasonable jury could find the defendant's conduct to be a 'substantial factor,' thereby limiting the scope of foreseeability. The decision serves as a significant precedent for alarm companies and other businesses whose products or services might indirectly relate to subsequent criminal acts, reinforcing that their liability will be severed when intervening acts are so extraordinary or remote that they break the chain of causation.
