Minor v. Zidell Trust
618 P.2d 392, 1980 Okla. LEXIS 336, 1980 OK 144 (1980)
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Rule of Law:
An independent, unforeseeable, and efficient intervening act, deemed a 'supervening cause,' can break the chain of proximate causation, thereby insulating prior alleged negligent actors from liability for the resulting harm.
Facts:
- An 86-year-old man (Motorist) drove to a local shopping center (Owner) and let his wife off at one of the shops.
- Motorist then attempted to park his automobile in the Owner’s second-story parking facility, which featured a 7¾-inch concrete curb and a 3-foot brick wall around its perimeter.
- While backing out of an initial parking space to seek another, Motorist noticed his preferred space was taken, and began to head back into his original stall.
- Motorist's car, while in motion or surging forward, went over the concrete wheel curb, crashed through the wall, and came to rest in the street below.
- Motorist lost consciousness while proceeding into the parking stall and does not remember pressing the accelerator or going over the curb.
- The investigating police officer found nine feet of acceleration marks left by the car's back wheels in the parking spot.
- Motorist alleged that the Owner and architects were negligent in the design and construction of the wheel curb and the wall behind it.
Procedural Posture:
- Motorist sued the Shopping Center Owner and its architects in a trial court, alleging negligence and strict liability for injuries sustained.
- The trial court granted summary judgment in favor of the Owner and architects, finding that proximate cause was lacking.
- Motorist appealed the trial court's summary judgment to the Supreme Court of Oklahoma.
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Issue:
Does the undisputed evidence regarding the proximate cause of Motorist's injuries raise only a single inference that the alleged negligence in the design and construction of a parking facility's curb and wall was not the proximate cause of those injuries?
Opinions:
Majority - Opala, Justice
Yes, the undisputed facts establish that the alleged negligence of the Owner and architects was not, as a matter of law, the proximate cause of Motorist's injuries. The court found that Motorist's lapse into unconsciousness and the subsequent uncontrolled acceleration of his car constituted a 'supervening cause.' To qualify as a supervening cause that breaks the chain of liability, an intervening cause must be (1) independent of the original act, (2) adequate of itself to bring about the result, and (3) not a reasonably foreseeable event. The court determined that Motorist's loss of consciousness and the ensuing 'wild' course of the vehicle were 'so unusual and extraordinary an event as to merit recognition as unforeseeable in law.' This independent, intervening act was deemed so overpowering that it broke the chain of causation, thereby insulating all prior causative factors, including any alleged negligence in the wall's design. The court affirmed that comparative negligence statutes do not alter proximate causation inquiries, and strict liability still requires a showing of proximate cause.
Dissenting - Simms, Justice
No, the traditional 'cause v. condition' analysis of proximate cause is misapplied in this case concerning the alleged defective design of an architect. Justice Simms argued that relying on this confusing analysis could prematurely eliminate design defect litigation, especially regarding safety devices, which are often designed to mitigate injuries even when negligence occurs. He contended that the majority's opinion effectively concludes that the Owner and architects had no duty to build an 'impregnable wall' rather than properly analyzing proximate causation. Justice Simms believed the majority confused foreseeability as an element of duty with foreseeability as a factor in proximate cause, pointing to cases that address a store owner's duty to erect barriers against runaway cars. Justice Williams joined in the dissent.
Analysis:
This case significantly clarifies and reinforces the 'supervening cause' doctrine in Oklahoma, emphasizing that an extraordinary and unforeseeable intervening event can completely sever the causal link between a defendant's alleged negligence and a plaintiff's injuries. It establishes a high bar for plaintiffs seeking to connect a defendant's actions to harm when a highly unusual event occurs. The decision also underscores the importance of distinguishing between a breach of duty and proximate cause, suggesting that even if a duty might hypothetically be breached, a supervening cause can negate liability based on causation. This ruling could influence future design defect cases by limiting liability for defects if an utterly unpredictable event intervenes, particularly regarding the scope of foreseeability required for proximate cause.
