Watson v. Ky. & Ind. Bridge & Ry Co.
1910 Ky. LEXIS 606, 137 Ky. 619, 126 S.W. 146 (1910)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
An original negligent actor is liable for injuries caused by a subsequent, intervening act if that act was a reasonably foreseeable consequence of the original negligence. However, a malicious or wanton intervening act is generally considered an unforeseeable superseding cause that breaks the chain of causation, relieving the original actor of liability.
Facts:
- A tank car owned by the Union Tank Line Company and operated by the Kentucky & Indiana Bridge & Railroad Company, filled with gasoline, derailed in a populous area of Louisville.
- The derailment broke the car's valve, causing all of its gasoline to leak out and flow into the street and gutters.
- The spilled gasoline created large quantities of highly explosive and combustible gas, which spread throughout the neighborhood.
- Approximately four hours after the derailment, a man named Charles Duerr struck a match near the spill.
- The match ignited the gas, causing a massive explosion.
- The explosion threw John Watson from his bed inside his home, partially demolishing the house and causing him severe injuries.
Procedural Posture:
- John Watson filed a lawsuit in the circuit court (trial court) against Kentucky & Indiana Bridge & Railroad Company, Union Tank Line Company, and two other railroads.
- At the conclusion of the evidence at trial, Watson dismissed the action against the two other railroads.
- The remaining defendants moved for a peremptory instruction (equivalent to a directed verdict).
- The trial court granted the defendants' motion, instructing the jury to find in their favor.
- The jury returned a verdict for the defendants, and the trial court entered a judgment accordingly.
- Watson's motion for a new trial was denied by the trial court.
- Watson, as appellant, appealed the judgment to the Court of Appeals of Kentucky.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is a defendant's initial negligence the proximate cause of an injury when that injury is directly triggered by the subsequent act of a third party, and the nature of that third party's act (whether negligent or malicious) is in dispute?
Opinions:
Majority - Judge Settle
Yes, a defendant's initial negligence can be the proximate cause of an injury even if a third party's act directly triggers it, as the determination of proximate cause and the nature of the intervening act are questions for the jury. The trial court erred by invading the province of the jury in determining that the intervening act was malicious as a matter of law. The court reasoned that the question of proximate cause is a question of fact for the jury. If Duerr's act of lighting the match was merely negligent or inadvertent, it would be a foreseeable consequence of the railroad's negligence in creating a massive gas leak in a public street. In that case, the railroad's negligence would be the proximate cause. However, if Duerr's act was malicious and done with the intent to cause an explosion, it would constitute an unforeseeable, superseding cause, breaking the chain of causation and relieving the railroad of liability. Because the evidence regarding Duerr's intent was conflicting, the jury, not the judge, should have decided whether his act was negligent or malicious. The court affirmed the dismissal against the Union Tank Line Company, as there was no evidence its car was defective before the derailment.
Analysis:
This case clarifies the doctrine of proximate cause, particularly regarding intervening acts. It establishes a critical distinction between a foreseeable, negligent intervening act and an unforeseeable, malicious one. The decision reinforces the principle that while a defendant is responsible for the reasonably foreseeable consequences of their negligence, they are not expected to anticipate criminal or wanton acts of others. By holding that the character of the intervening act is a question of fact for the jury when evidence is in conflict, the ruling limits the power of judges to decide causation as a matter of law in such circumstances.
