Brief Fact Summary. Plaintiff lived with Defendant police officer who owned a gun and stored it loaded and unlocked in the bedroom.Â One night after consuming drugs and being asked by Defendant to move out, Plaintiff took the gun from the bedroom and shot at Defendant twice but the gun did not fire.Â Plaintiff then shot herself and the gun did fire, seriously injuring her.Â She sued Defendant for negligence.
Synopsis of Rule of Law. In most states, suicide is considered an intervening cause which breaks the chain of causation, relieving a defendant from liability.Â A few states, however, including Massachusetts, do not follow this traditional rule and will allow a plaintiff the chance to show that the risk of suicide was foreseeable and that defendant proximately caused it.
The Court of Appeals noted: Courts generally decline to impute a duty to the defendant when he neither caused the decedent's uncontrollable suicidal impulse nor had custody of the decedent and knowledge of her suicidal ideation.View Full Point of Law
Issue. Â Whether suicide is such an extraordinary event as not to be reasonably foreseeable, but an intervening cause of injury which breaks the chain of causation.No, under Massachusetts law.Â Historically, a purposeful act of suicide, rather than any antecedent negligence, will be deemed the legal cause of a decedent’s injury unless the defendant’s negligence rendered the decedent unable to appreciate the self-destructive nature of the suicidal act or unable to resist the suicidal impulse.Â Massachusetts, however, does not adopt an ironclad rule that suicide constitutes an intervening cause.Â The court held that Delaney should have the chance to show that the risk that she would handle Reynolds’ gun in a manner so as to cause intentional injury to herself was foreseeable and that his failure to secure his gun was a proximate cause of her injury.Â Accordingly, the appeals court revered the summary judgment ruling.
Discussion. Â Most states continue to follow the traditional rule that suicide is a superseding cause of plaintiff’s harm, freeing the defendant from liability for negligence.Â Like Massachusetts, however, other jurisdictions have recently gone beyond the categorical basis for treating suicide as an intervening cause of injury and have considered various nontraditional circumstances as relevant to the issue of foreseeability.