Jarvis v. JI Case Co.
551 So.2d 61, 1989 WL 120491 (1989)
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Rule of Law:
In a comparative fault jurisdiction, a plaintiff's own negligent conduct that contributes to an injury does not entitle defendants to summary judgment on the issue of causation. If a defendant's allegedly defective product or negligent act is also a potential cause-in-fact of the harm, the question of causation and the apportionment of fault must be decided by the trier of fact.
Facts:
- Harry Jarvis was an experienced repair crew foreman for the City of Baker.
- Weeks prior to the accident, city workers used a solvent, Bitumastic No. 50 manufactured by Koppers, on a PVC gas pipe manufactured by Certainteed.
- The solvent allegedly caused the PVC pipe to soften and rupture, resulting in a natural gas leak.
- On December 10, 1984, Jarvis's crew was dispatched to repair the leak.
- Jarvis operated a backhoe, manufactured by J.I. Case Co., with an engine manufactured by Teledyne and installed by B & L Group, Inc.
- Before the gas line was shut off, Jarvis positioned the operating backhoe over the area of the gas leak.
- The backhoe's engine allegedly backfired, igniting the leaking natural gas and causing an explosion.
- Jarvis was severely burned in the explosion.
Procedural Posture:
- Harry and Dorothy Jarvis filed suit in a Louisiana trial court against Certainteed Corporation, Koppers Company, Inc., J.I. Case Corporation, Teledyne Wisconsin Motor, and B & L Group, Inc., alleging negligence and strict products liability.
- All defendants filed motions for summary judgment, arguing they were not liable as a matter of law.
- The trial court granted the summary judgments, dismissing all defendants from the case.
- The plaintiffs, Harry and Dorothy Jarvis, appealed the trial court's grant of summary judgment to the Court of Appeals of Louisiana, First Circuit.
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Issue:
Are manufacturers of allegedly defective products entitled to summary judgment on the grounds that a plaintiff's own negligent conduct was the sole cause of his injury, even when the manufacturers' products may have also been a cause-in-fact of the harm?
Opinions:
Majority - Watkins, Judge
No. The manufacturers are not entitled to summary judgment because the existence of multiple causes-in-fact, including the plaintiff's own negligence, creates a question for the trier of fact. The court reasoned that under Louisiana's comparative fault system, a plaintiff's negligence serves to reduce recovery, not to act as an absolute bar. The defendants' argument that Jarvis's action was the sole cause of the injury fails to acknowledge that there can be several causes-in-fact that combine to produce an injury. So long as any causal connection, however slight, exists between a defendant's product and the harm, the issue presents a jury question and summary judgment is inappropriate.
Analysis:
This decision reinforces the principle that causation is a question of fact, particularly in jurisdictions that have adopted comparative fault. The court's ruling curtails the defense strategy of arguing that a plaintiff's contributory negligence constitutes the 'sole cause' of an injury to obtain summary judgment. It ensures that cases involving multiple potential causes proceed to trial, where a jury can apportion fault among all responsible parties, including the plaintiff. This preserves the plaintiff's 'day in court' and aligns the summary judgment standard with the principles of comparative negligence.
