Barry v. Quality Steel Products, Inc.

Brief Fact Summary.

The Barry’s and Cohade’s sued Quality Steel Products, Inc. (Quality Steel) and Rings End, Inc. after they were injured working on the roof of a construction site that used Quality Steel’s brackets.

Synopsis of Rule of Law.

The jury should determine whether each individual defendant’s action was a proximate cause of the plaintiff’s injuries in establishing the causes of a plaintiff’s injuries.

Facts.

The Cohades and the Barrys were injured working on the roof of a construction site with brackets manufactured by Quality Steel Products, Inc. and sold by Rings End, Inc. The Barrys and the Cohades (Carpenters) sued Quality Steel Products, Inc. (Quality Steel) and Ring’s End, Inc. (Ring’s End). Although the jury ultimately ruled in favor Quality Steel and Ring’s End, the jury found that the brackets used on the roof were the proximate cause of the Carpenters’ injuries. The Carpenters appealed on the theory of superseding cause.

Issue.

In establishing the causes of a plaintiff’s injuries, should the jury determine whether each individual defendant’s action was a proximate cause of the plaintiff’s injuries?

Held.

Yes. Reversed and remanded.

Discussion.

Although the doctrine of superseding cause relieves the defendant form liability if a third party’s conduct resulted in the plaintiff’s injury, Connecticut is a comparative negligence jurisdiction, allowing liability to be divided between the defendants. The jury therefore should be measuring whether each actor was a proximate cause of the plaintiff’s injuries, rendering the superseding cause instruction an error.