Welch v. Hesston Corp.
540 S.W.2d 127, 1976 Mo. App. LEXIS 2178 (1976)
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Rule of Law:
Under Missouri's 'rescue doctrine,' a person who voluntarily attempts to rescue property from a danger created by another's negligence is barred from recovering for injuries sustained during the rescue because their action is deemed a superseding, intervening cause that breaks the chain of proximate causation.
Facts:
- Hesston Corporation designed and manufactured a haystacker with a short hitch, which created a fire risk when used with a dual-wheeled tractor due to friction from the wheels rubbing a protective shield.
- Defendant Adams purchased a Hesston haystacker and was operating it with a dual-wheeled tractor on a farm.
- While Adams was making repeated sharp turns with the tractor, the friction caused a fire to erupt in the haystacker.
- The plaintiff, a retired volunteer fireman, was recruited to help extinguish the fire.
- After dousing the visible flames with water, the plaintiff suspected the hay inside the machine was still smoldering.
- To save the property, the plaintiff climbed into the steam- and smoke-filled haystacker to attach chains to pull the hay out.
- While inside, the plaintiff fell through a hole into hay that was still burning beneath the surface, resulting in severe burns to his leg.
Procedural Posture:
- The plaintiff filed a lawsuit in the trial court against Adams for negligent operation and against Hesston Corporation for defective design.
- The case was tried before a jury, which returned a verdict for the plaintiff, awarding him $10,000.
- Defendants Adams and Hesston Corporation (appellants) appealed the jury's verdict to the Missouri Court of Appeals, the intermediate appellate court.
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Issue:
Does a person's voluntary attempt to rescue property, as opposed to a person, from a negligently created danger constitute a superseding cause that breaks the chain of proximate causation and bars recovery for their injuries as a matter of law?
Opinions:
Majority - McMillian, J.
Yes. A person's voluntary act of rescuing property is a superseding cause that bars recovery for injuries sustained during the rescue. The court reasoned that Missouri's 'rescue doctrine,' which allows a rescuer to recover for injuries from the original tortfeasor, applies only to the rescue of human life, not property. This distinction is based on a policy choice that values human life above property; one may not voluntarily risk injury to save property and then hold the original negligent party liable. The plaintiff's deliberate and voluntary act of climbing into the smoldering haystacker was not a rescue of a person and therefore was not foreseeable in a way that preserves proximate cause. The defendants' negligence merely created the condition for the injury, but the plaintiff's own intervening act was the direct and legally efficient cause of his injuries, precluding recovery as a matter of law.
Analysis:
This decision reaffirms Missouri's strict, minority-view application of the rescue doctrine, creating a bright-line rule that distinguishes between rescuing persons and rescuing property. It solidifies the principle that attempting to save property is an intervening, superseding cause that breaks the chain of liability, meaning rescuers of property act at their own legal risk. The court's characterization of proximate cause as a 'policy decision on the limits of liability' rather than a pure question of foreseeability is a key jurisprudential takeaway. This ruling significantly impacts negligence cases by limiting a defendant's liability scope and placing the onus of risk on individuals who choose to protect property over their own safety.
