Addis v. Steele

Inn guests sued the innkeepers for negligence after a fire. The trial judge directed verdicts for the defendants. Plaintiffs appealed.

A fire of incendiary origin broke out at the inn at night. Emergency lighting was absent and exits were unlit, and the guests were injured jumping from a window.

Whether the criminal act of an arsonist is a superseding cause relieving an innkeeper of liability for failing to provide adequate emergency egress.

A defendant whose negligence creates a foreseeable risk of harm is not relieved of liability because the immediate triggering event is an intervening criminal act of the same general character as the risk.

No. The question of foreseeability was for the jury; directed verdicts were error.

Fire, however started, is the precise hazard against which emergency lighting and marked exits guard. The innkeeper's duty runs to the consequences of fire rather than its cause.

Superseding cause; foreseeability of intervening criminal conduct.

Judgments reversed; cases remanded for trial.

No separate opinions were filed.

Pitfall: do not conflate cause-in-fact with proximate cause. The arson satisfies but-for causation for both parties.

Frequently cited in premises-liability cases involving third-party criminal acts.

Palsgraf v. Long Island R.R. Co., 248 N.Y. 339 (1928).