Edwards v. Honeywell

Brief Fact Summary.

Edwards (plaintiff) sued Honeywell (defendant) for negligence.

Synopsis of Rule of Law.

For a defendant’s conduct to be the proximate cause of the plaintiff damages, the plaintiff must be a foreseeable victim.

Facts.

The defendant installed an alarm system in a home and the owners of the home paid for the system. One day a fire broke out in the basement and the alarm alerted a dispatcher at the defendant’s company. The defendant listed the fire department to be called in the owners of the home’s account information. However, the defendant listed the wrong firefighting crew, which caused a 4-minute delay in the firefighters arriving. As the fire fighter entered the house the floor caved in from under him, and he fell in the basement and died. The plaintiff sued arguing that the defendant was negligent in listing the wrong firefighting crew and this conduct caused the delay, which caused the house to be compromised at the time the firefighters arrived.

Issue.

Whether for a defendant’s conduct to be the proximate cause of the plaintiff damages, the plaintiff must be a foreseeable victim.

Held.

Yes. For a defendant’s conduct to be the proximate cause of the plaintiff damages, the plaintiff must be a foreseeable victim.

Concurrence.

None

Discussion.

Negligence requires that the defednat conduct must be the actual and proximate cause of the plaintiff’s damage. To be the proximate cause of the plaintiff’s injuries the plaintiff must be foreseeable and if the plaintiff is unforeseeable then the defendant cannot be held liable for negligence. Only plaintiffs the defendant could have anticipated can be a foreseeable victim. If tort law would hold defendants liable for unforeseeable victims, the tort of negligence would have no deterrent effect. Here, the plaintiff was an unforeseeable victim because the defendant could have done nothing to prevent the fire, they alert someone if there is a fire. Holding them liable would have no deterrent effect.