Northington v. Marin

Brief Fact Summary.

Northington filed a negligence suit against Marin claiming that Marin spread rumors in Denver County Jail that Northington was a snitch, resulting in various assaults from the other inmates.

Synopsis of Rule of Law.

An actor’s negligence is a substantial factor in bringing about harm if two forces are sufficient enough to bring each other harm individually, and ne of the two forces exists due to the actor’s negligence.

Facts.

Northington was assaulted in jail several times after inmates accused Northington of being a snitch. Northington filed a negligence suit against Marin claiming that Marin spread rumors in Denver County Jail that Northington was a snitch, resulting in various assaults from the other inmates. The district court founded in favor of Northington.

Issue.

Whether an actor’s negligence is a substantial factor in bringing about harm if two forces are sufficient enough to bring each other harm individually, and one of the two forces exists due to the actor’s negligence?

Held.

Yes. The judgment of the district court is affirmed. Marin and the other deputies were a substantial factor in causing the assaults against Northington. Because there was no determination regarding the extent to which Marin or the other deputies contributed to the harm, Marin was held liable for the entire harm.

Discussion.

An actor’s negligence is a substantial factor in bringing about harm if two forces are sufficient enough to bring each other harm individually, and ne of the two forces exists due to the actor’s negligence. If two forces cause a harm, and it cannot be determined which of the two forces caused the harm, then the actors behind each of the forces can be held liable for the harm.