The question of proximate cause under Maryland law is not whether a defendant's negligence could reasonably be expected to cause the plaintiff's specific injury, but whether such negligence could reasonably be expected to cause the plaintiff any injury.
Defendant owned a hotel at which plaintiff was a guest. The fire alarm at the hotel sounded after a cleaning crew failed to turn on an exhaust system while cleaning an oven in the kitchen. Plaintiff was staying on the 14th floor and was forced to evacuate the building using the stairs. After reaching the ground floor, she experienced shortness of breath and needed oxygen support. The next day, plaintiff continued to have breathing problems and experienced chest pain. She was determined to have suffered a collapsed lung. Plaintiff sued defendant for negligence, claiming that her collapsed lung was caused by defendant’s negligence in failing to turn on the exhaust fans during the cleaning. At trial, the district court granted defendant’s motion for summary judgment, finding that plaintiff had failed to show that defendant's negligence was the proximate cause of plaintiff’s injury. Plaintiff appealed the decision.
Did the lower court used the proper proximate cause standard in granting the defendant's motion for summary judgment?
On review, the court found that the question of proximate cause was not whether the hotel's negligence could reasonably have been expected to cause plaintiff's specific injury, but whether such negligence could reasonably have been expected to cause plaintiff any injury. The court held that under the field of danger analysis the question was whether the hotel might have anticipated that plaintiff might have suffered injury as a consequence of evacuating the hotel by taking the stairs when the hotel's negligence caused the fire alarm to go off. Because that question could have been answered either way, summary judgment was not proper.