Part 2- Crimes and Torts, Chapter 7: Negligence and Strict Liability, Doc 6

Summary: Duty, Proximate Cause, and Intervening Causes in Negligence This discussion centers on the principles of duty of care, proximate cause, and intervening causes in tort law, and provides examples from cases to illustrate how courts determine a defendant's liability in negligence, even when additional factors contribute to the outcome. 1. Proximate Cause and Duty of Care Key Principles: • • Proximate Cause: Courts limit liability in negligence to injuries that are reasonably foreseeable or the “natural and probable consequences” of the defendant’s actions. For example, if a defendant's negligence led directly to a predictable outcome, they might be held liable. However, if an injury is highly unusual or extraordinary, it may not meet proximate cause criteria. Scope of Foreseeable Risk: Some courts rule that defendants owe a duty only to those foreseeable as victims of their actions. For instance, if a pedestrian is hit by a car due to a driver’s excessive speed, the injury is a foreseeable risk of the driver’s negligence. In Black v. William Insulation Co., an employee’s exhaustion from long hours and a long commute led to a car accident resulting in a passenger's death. The plaintiff argued that the employer should be responsible due to conditions contributing to the employee's fatigue. However, the court found: • • No Duty Owed: The employer did not owe a duty to protect the motoring public from an employee’s fatigue, especially as the worker's exhaustion stemmed from personal choices (e.g., a second job and a voluntary long commute). Proximate Cause: The court concluded that the employee’s personal decisions, not the employer’s actions, were the substantial cause of the accident, and thus WIC’s duty did not extend to this scenario. 2. Intervening Causes and Liability An intervening cause occurs when a third-party action or event after the defendant's breach contributes significantly to the harm. Courts consider whether the intervening event was foreseeable to determine if it absolves the defendant of liability: • • Foreseeable Intervening Causes: If the intervening cause, such as natural elements or routine criminal activity in a high-crime area, is foreseeable, the defendant may still be held liable. Unforeseeable Intervening Causes: When the later event is unforeseeable and extraordinary, it may absolve the defendant of responsibility. In Stahlecker v. Ford Motor Co., Amy Stahlecker’s vehicle became inoperable due to a faulty Firestone tire, leaving her stranded where she was abducted and murdered. Her parents argued that Ford and Firestone’s negligence (in selling a defective tire without adequate warnings) created a dangerous condition that led to their daughter’s harm. However, the court ruled: • No Liability for Unforeseeable Harm: The criminal acts of the abductor were an unforeseeable intervening cause, breaking the causation chain. Despite Ford and Firestone’s potential fault in causing the vehicle failure, the murder was not a predictable outcome of the tire defect, thus absolving them of liability. These cases illustrate how proximate cause and intervening cause principles guide courts in limiting negligence liability to harms closely linked to a defendant’s actions. Courts weigh the foreseeability of outcomes, the defendant’s control over the risk, and whether the injury was a direct result of the defendant’s conduct or an unforeseeable event.