Ingersoll v. Liberty Bank of Buffalo
14 N.E.2d 828 (1938) (1938)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A plaintiff in a negligence action establishes a prima facie case of causation when they demonstrate facts and conditions from which the defendant's negligence, and the causation of the accident by that negligence, may be reasonably inferred. The plaintiff is not required to eliminate all other remote or merely possible causes of the injury.
Facts:
- The decedent was a tenant in a two-family house owned by the defendant.
- A single wooden stairway leading to the basement, used by all tenants, was in a defective condition, with worn, shaky treads and a cracked step second from the bottom.
- The defendant was notified of the stairway's dangerous condition but failed to make repairs.
- On the day of the incident, the decedent, a man weighing 214 pounds, started down the basement stairs carrying a 32-pound box.
- His wife then heard a crash and found the decedent at the foot of the stairs, injured.
- Immediately after the fall, the decedent told his wife "Something broke," and then, pointing to his chest, said, "Something gave away in here."
- An inspection of the stairway after the incident revealed that a piece of the cracked second step had broken off, exposing an old crack.
- The decedent died several months later, and medical testimony at trial linked his death to the injuries from the fall.
Procedural Posture:
- The plaintiff, the decedent's widow, sued the defendant landlord in the trial court for negligence.
- The jury returned a verdict in favor of the plaintiff.
- The trial court denied the defendant's motion for a new trial.
- The defendant, as appellant, appealed to the Appellate Division (an intermediate appellate court).
- The Appellate Division reversed the judgment and dismissed the complaint, finding no causal connection was proven.
- The plaintiff, as appellant, then appealed to the Court of Appeals of New York (the state's highest court).
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a plaintiff in a negligence action establish a prima facie case of causation sufficient for jury consideration by showing facts from which the defendant's negligence can be reasonably inferred as the cause of injury, even if other remote, alternative causes might exist?
Opinions:
Majority - Finch, J.
Yes. A plaintiff establishes a prima facie case of causation when the facts presented allow for a reasonable inference that the defendant's negligence caused the injury, even without positively excluding every other remote possibility. Here, the natural and reasonable inference is that the decedent, a large man carrying a heavy box, stepped on the known defective tread, which broke under the weight and caused him to fall. The defendant's alternative theories—that the decedent had a heart attack or fainted and dropped the box, which then broke the step—are remote possibilities. The law does not require a plaintiff to disprove every conceivable cause; it is sufficient to show that the defendant's negligence is the more probable cause. Unlike cases where multiple causes are equally plausible, here the evidence strongly favors the plaintiff's theory, making causation a question of fact for the jury to decide. However, because the trial court improperly admitted the decedent's statement 'something broke' which was not part of the res gestae, a new trial is required.
Analysis:
This decision clarifies the standard for proving causation with circumstantial evidence in negligence cases. It establishes that a plaintiff can defeat a motion for dismissal by showing their theory of causation is reasonable and probable, without needing to definitively disprove every alternative explanation offered by the defendant. The ruling distinguishes between competing causes that are 'equally reasonable' (where the plaintiff fails) and those where the defendant's proposed cause is merely a 'remote possibility' (where the case should go to the jury). This lowers the barrier for plaintiffs in cases where direct evidence is unavailable, empowering juries to make logical inferences from the facts presented.
Unlock the full brief for Ingersoll v. Liberty Bank of Buffalo