Von Der Heide v. Commonwealth of Pennsylvania Department of Transportation
1998 Pa. LEXIS 2121, 553 Pa. 120, 718 A.2d 286 (1998)
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Rule of Law:
The doctrine of superseding cause applies only to the unforeseeable acts of a third person or other external force. A plaintiff's own conduct, regardless of how extraordinary, must be analyzed under the principles of comparative negligence and cannot constitute a superseding cause that absolves the defendant of liability.
Facts:
- William Von der Heide was driving his family south on Route 15 in his Plymouth Acclaim.
- For reasons that are not specified, his car crossed over the opposing northbound lane of traffic.
- After leaving the roadway, the car struck a guardrail and traveled along it for approximately seventeen feet.
- The vehicle came to a final stop upon striking a concrete bridge abutment, and Mr. Von der Heide sustained fatal injuries from the crash.
Procedural Posture:
- Alice Von der Heide, on behalf of her husband's estate, filed a wrongful death lawsuit against the Pennsylvania Department of Transportation (PennDOT) in the trial court.
- Following a trial, the jury found PennDOT 60% negligent and the decedent 40% negligent, and awarded damages.
- PennDOT filed a post-trial motion for a new trial, arguing the trial court erred by refusing to provide a jury instruction on superseding cause.
- The trial court granted PennDOT's motion and ordered a new trial.
- Appellee Alice Von der Heide appealed the trial court's order granting a new trial to the Commonwealth Court, an intermediate appellate court.
- The Commonwealth Court reversed the trial court's order and reinstated the original jury verdict.
- Appellant PennDOT then appealed the Commonwealth Court's decision to the Supreme Court of Pennsylvania.
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Issue:
Does the doctrine of superseding cause apply to the conduct of a plaintiff, thereby requiring a trial court to instruct the jury that the plaintiff's own negligence could be a superseding cause that absolves the defendant of all liability?
Opinions:
Majority - Justice Nigro
No. The doctrine of superseding cause is inapplicable to a plaintiff’s conduct, as it requires an intervening act by a third person or other external force to break the chain of causation from the defendant's negligence. The court reasoned that superseding cause and comparative negligence are distinct legal concepts. Superseding cause involves an unforeseeable act by a third party that becomes the legal cause of the harm, completely relieving the original defendant of liability. In contrast, comparative negligence involves assessing the plaintiff's own negligent conduct alongside the defendant's to apportion fault. Here, there was no third party involved; the only conduct at issue was that of the defendant (PennDOT) and the plaintiff (Mr. Von der Heide). Therefore, Mr. Von der Heide's actions, such as allegedly falling asleep, were properly considered by the jury under comparative negligence principles, not as a potential superseding cause.
Concurring - Justice Saylor
No. While concurring with the majority's conclusion that a superseding cause instruction was unwarranted in this case, the concurrence suggests that the majority's rule might be too absolute. Justice Saylor would not entirely foreclose the possibility that a plaintiff's conduct could, in a rare and appropriate case, be deemed a superseding cause. Specifically, this might apply where a plaintiff's conduct is intentional, wholly unforeseeable, and creates a risk entirely distinct from the defendant's negligence. However, since Mr. Von der Heide's conduct was neither intentional nor unforeseeable in the context of a car accident, the doctrine does not apply here.
Analysis:
This decision firmly distinguishes the doctrines of superseding cause and comparative negligence in Pennsylvania, preventing their conflation. It clarifies that a defendant cannot use a plaintiff's own negligence as both a basis for apportioning fault under comparative negligence and as a complete defense under the superseding cause doctrine. This holding reinforces the structure of tort liability by reserving the powerful, all-or-nothing defense of superseding cause for truly external, intervening events caused by third parties. Future cases involving only the actions of a plaintiff and a defendant will be analyzed strictly within the comparative fault framework, providing more predictability in litigation.
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