La Quinta Inns, Inc. v. Leech

Court of Appeals of Georgia
658 S.E.2d 637 (2008)

ELI5:

Rule of Law:

A person's suicide is generally an unforeseeable intervening act that breaks the chain of proximate cause, absolving a defendant of liability for negligence. Additionally, a premises owner is not liable for an invitee's injuries caused by a dangerous condition if the invitee's knowledge of the danger was equal or superior to the owner's.

Facts:

John Leech, a long-term guest at a La Quinta Inn, had a confrontation with his daughter, Ashley, about his extramarital affair.
Shortly after midnight, Leech returned to the hotel and booked a second room on the seventh floor for a friend.
Leech's son, James, and friend, Rivera, arrived at the hotel and were denied Leech's room number by the front desk clerk, Linda Cotton.
During a subsequent phone call at approximately 1:13 a.m., Leech made statements to his son that James interpreted as threats of self-harm.
James and Rivera immediately informed Cotton that Leech was threatening to harm himself and urged her to call 911 and provide the room number.
Overhearing his son's demands to Cotton, Leech told James, "it would be over before [he] got [there]," and ended the call.
At 1:38 a.m., James forced entry into Leech's seventh-floor room and found it empty, with an open window that lacked the required safety stops, and saw his father's body on the ground below.
Leech had no prior history of depression or threats of suicide.

Procedural Posture:

Carol Leech, as representative of John Leech's estate, filed a wrongful death action against La Quinta Inns, Inc. and Linda Cotton in the trial court.
The plaintiff alleged two alternative theories: (1) negligent failure to prevent suicide and (2) negligent maintenance of hazardous premises leading to an accidental fall.
The defendants filed a motion for summary judgment on both claims.
The trial court denied summary judgment on the suicide theory but granted summary judgment for the defendants on the accidental fall theory, ruling the evidence demanded a finding of suicide.
The defendants, La Quinta and Cotton, were granted an interlocutory appeal to the Court of Appeals of Georgia on the denial of their summary judgment motion (appellants).
The plaintiff, Carol Leech, filed a cross-appeal on the grant of summary judgment against her accidental fall claim (appellee/cross-appellant).

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Issue:

Does a person's suicide constitute an unforeseeable intervening act that breaks the chain of proximate cause for a hotel's alleged negligence, and is a hotel liable under a premises liability theory for a hazardous window when the guest's knowledge of the danger was equal to the hotel's?

Opinions:

Majority - Ellington, Judge

No. A person's voluntary act of suicide is generally an unforeseeable intervening act that breaks the causal chain from a defendant's alleged negligence, becoming the sole proximate cause of the death. Further, a premises owner is not liable for a dangerous condition if the injured party's knowledge of the risk was equal to the owner's. In the first claim, Mr. Leech's act of suicide was the sole proximate cause of his death, rendering any theory that La Quinta's alleged delay in response could have prevented it purely speculative. Suicide is an unforeseeable intervening cause that absolves the alleged tortfeasor of liability. In the second claim, even assuming the death was accidental, the danger posed by a large, open window on the seventh floor was an obvious hazard. Mr. Leech's knowledge of this danger was at least equal to that of La Quinta, especially since his own action of opening the window created the final risk. The basis for premises liability is the proprietor's superior knowledge of a hazard, which is absent here.

Analysis:

This decision reinforces two significant defenses in tort law. First, it strongly affirms that suicide is a superseding cause that severs the chain of proximate causation, making it very difficult for plaintiffs to hold third parties liable for failing to prevent a suicide absent a special relationship or direct causation. Second, it strictly applies the 'equal knowledge' rule in premises liability, confirming that a property owner is not liable for injuries resulting from open and obvious dangers, even if a technical defect (like missing window stops) exists. The ruling underscores that an invitee's awareness of a risk can defeat a claim of negligence against the property owner.

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