McDaid v. Aztec W. Condo. Ass'n
234 N.J. 130, 189 A.3d 321 (2018)
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Rule of Law:
The doctrine of res ipsa loquitur applies when a person is injured by a malfunctioning elevator door, allowing for a permissive inference of negligence against the parties in exclusive control. The plaintiff is not required to exclude all other possible non-negligent causes of the malfunction to invoke the doctrine.
Facts:
- Maureen McDaid, a resident with cerebral palsy, lived at the Aztec West Condominium.
- In mid to late September 2010, McDaid complained to the property manager, Howard Gartenberg, that the elevator door was 'closing too fast.'
- Gartenberg communicated this complaint to the elevator maintenance provider, Bergen Hydraulic Elevator.
- On October 14, 2010, as McDaid was exiting the elevator, the doors closed on her, knocking her to the ground.
- While she was on the ground, the doors opened and then closed on her a second time, causing serious injuries.
- Four days later, a city construction code official inspected the elevator and determined that its 'electric eye' safety feature was in need of repair.
- Shortly thereafter, Bergen Hydraulic confirmed that the electric eye's relay contacts were 'not functioning properly' and repaired the device.
- Aztec West Condominium Association had maintenance contracts with Preferred Management, Inc., and Bergen Hydraulic Elevator for the building's common areas and elevator.
Procedural Posture:
- Maureen McDaid filed a negligence lawsuit in a New Jersey trial court against Aztec West Condominium Association, Preferred Management, Inc., and Bergen Hydraulic Elevator.
- At the close of discovery, all defendants moved for summary judgment.
- The trial court granted summary judgment for the defendants, dismissing McDaid's complaint on the grounds that res ipsa loquitur did not apply and McDaid failed to show defendants had notice of a defect.
- McDaid, as appellant, appealed the trial court's decision to the Appellate Division.
- The Appellate Division affirmed the trial court's grant of summary judgment in an unreported opinion.
- McDaid then petitioned the Supreme Court of New Jersey for certification, which the court granted.
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Issue:
Does the doctrine of res ipsa loquitur apply when a person is injured by a malfunctioning elevator door, allowing for an inference of negligence against the parties in exclusive control of the elevator?
Opinions:
Majority - Justice Albin
Yes, the doctrine of res ipsa loquitur applies when a person is injured by a malfunctioning elevator door because common experience indicates that such an incident ordinarily bespeaks negligence. The court reasoned that there is no rational distinction between a malfunctioning automatic supermarket door, as addressed in Jerista v. Murray, and a malfunctioning elevator door. The first prong of the res ipsa test—that the occurrence ordinarily bespeaks negligence—is satisfied based on the common knowledge that elevator doors, however complex, should not close on and injure a passenger in the absence of negligence. The court explicitly held that to gain this inference, a plaintiff does not need to provide expert testimony to pinpoint the specific cause of the malfunction or to exclude other possible non-negligent causes. The doctrine properly places the burden of explanation on the defendants who maintain exclusive control over the instrumentality and are in a superior position to explain what went wrong.
Analysis:
This decision significantly clarifies and strengthens the application of res ipsa loquitur in New Jersey for cases involving complex instrumentalities. By extending the reasoning from Jerista (automatic doors) to elevators, the court creates a consistent legal standard and lowers the initial evidentiary burden for plaintiffs injured by such machinery. The ruling effectively overrules prior appellate decisions that had required plaintiffs to exclude other potential causes of failure, making it easier for such negligence cases to survive summary judgment and reach a jury. This precedent reinforces the principle that those in exclusive control of potentially dangerous equipment are best positioned to explain failures, shifting the burden of production to them once a plaintiff establishes a prima facie case through the res ipsa inference.
