Hellums v. Raber

853 N.E.2d 143, 2006 Ind. App. LEXIS 1719, 2006 WL 2457410
CourtIndiana Court of Appeals
DecidedAugust 25, 2006
Docket14A01-0602-CV-68
StatusPublished
Cited by15 cases

This text of 853 N.E.2d 143 (Hellums v. Raber) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hellums v. Raber, 853 N.E.2d 143, 2006 Ind. App. LEXIS 1719, 2006 WL 2457410 (Ind. Ct. App. 2006).

Opinions

[145]*145OPINION

CRONE, Judge.

Case Summary

Charles D. Heliums appeals the trial court’s grant of Alan Raber’s motion for summary judgment. We reverse and remand.

Issue

We restate the issue as whether there is a genuine issue of material fact as to whether Alan’s actions were a proximate cause of Heliums’s injuries. .

Facts and Procedural History

On November 15, 2003, a partly sunny day with no precipitation, Alan was hunting deer with William Nugent and his cousin, Ernest Raber. Heliums was with a separate party hunting deer on the same property. Alan had seen another truck parked on the property with a “kid” standing next to it and had assumed that there were other people hunting there. Appellant’s App. at 119. As they were walking through a field, Alan’s party spotted a deer, and each member of his party shot at the deer. Alan claims that he fired four rapid shots at the deer. Alan’s party moved forward to determine whether they had hit the deer. About five to ten seconds later, a second deer came into view, running in approximately the same direction as the first. Ernest fired multiple shots at this deer, and one of his bullets struck Heliums. According to Nugent, Alan might have also shot at this deer. However, all parties acknowledge that the bullet that struck Heliums did not come from Alan’s gun.

Heliums’s party had spotted Alan’s party before they began shooting at the first deer. Heliums estimates that they were about 175 to 200 yards to the east of Alan’s party. Heliums and his father were both wearing orange hats. Heliums waved his hat at Alan’s party, hoping to get their attention. When the second deer came into view, Heliums and his father began shouting as well, but unfortunately did not get the attention of Alan’s party in time.

On September 22, 2004, Heliums filed suit against Alan, Ernest, and Nugent, alleging that they had been negligent in failing to ascertain the presence of other hunters before shooting. Id. On November 17, 2005, Alan moved for summary judgment on the basis that Heliums was not hit by a bullet from his gun, and that he therefore had not proximately caused Heliums’s injuries. The trial court granted Alan’s motion on December 12, 2005.

Discussion and Decision

Heliums asserts that the trial court erred in granting Alan’s motion for summary judgment. Our standard of review is well settled:

While the party losing in the trial court must persuade us that the trial court’s decision was erroneous, we face the same issues as did the trial court and analyze them in the same way. Summary judgment is appropriate only if the pleadings and evidence show both the absence of a genuine issue of material fact and that the moving party is entitled to judgment as a matter of law. The evidence before the court must be liberally construed in the light most favorable to the non-moving party. Where material facts conflict, or undisputed facts lead to conflicting material inferences, summary judgment is inappropriate. We carefully scrutinize a trial court’s grant of summary judgment to assure that the losing party is not improperly prevented from having its day in court.

Butler v. City of Indianapolis, 668 N.E.2d 1227, 1228 (Ind.1996) (citations omitted).

The elements of negligence are duty, breach of duty, and damages proxi[146]*146mately caused by the breach. Webb v. Jarvis, 575 N.E.2d 992, 995 (Ind.1991). The main point of contention between the parties is whether Alan’s actions were a proximate cause of Heliums’s injuries.

An essential element in a cause of action for negligence is the requirement of a reasonable connection between a defendant’s conduct and the damages which a plaintiff has suffered. This element requires, at a minimum, causation in fact — that is, that the harm would not have occurred “but for” the defendants’ conduct. The “but for” analysis presupposes that, absent the tortious conduct, a plaintiff would have been spared suffering the claimed harm.

Daub v. Daub, 629 N.E.2d 873, 877 (Ind.Ct.App.1994) (citations omitted), trans. denied. “The proximate cause of an injury is not merely the direct or close cause, rather it is the negligent act which resulted in an injury which was the act’s natural and probable consequence in light of the circumstances and should reasonably have been foreseen and anticipated.” City of Indianapolis Housing Auth. v. Pippin, 726 N.E.2d 341, 346 (Ind.App.2000). An injury may have more than one proximate cause. Id. Proximate cause is generally a question of fact, and therefore summary judgment is rarely appropriate in negligence cases. Correll v. Ind. Dep’t of Transp., 783 N.E.2d 706, 707 (Ind.Ct.App.2002), trans. denied.

The parties agree that Heliums was not injured by a bullet from Alan’s gun. Heliums alleges, however, that Alan shot his gun negligently and that this encouraged Ernest to shoot negligently as well. He argues that multiple hunters may be held liable for a plaintiffs injuries even when it is possible to determine which one shot the plaintiff. As there is no Indiana case law directly on point, Hel-iums urges us to adopt the position of the Restatement (Second) of Torts. Section 876 of the Restatement states:

For harm resulting to a third person from the tortious conduct of another, one is subject to liability if he (a) does a tortious act in concert with the other or pursuant to a common design with him, or (b) knows that the other’s conduct constitutes a breach of duty and gives substantial assistance or encouragement to the other so to conduct himself, or (c) gives substantial assistance to the other in accomplishing a tortious result and his own conduct, separately considered, constitutes a breach of duty to the third person.

Heliums argues that this case falls under clause (b). The Restatement’s comments to clause (b) contain the following example: “A and B are members of a hunting party. Each of them in the presence of the other shoots across a public road at an animal, which is negligent toward persons on the road. A hits the animal. B’s bullet strikes C, a traveler on the road. A is subject to liability to C.” This example is based on cases from several other jurisdictions. See Orser v. Vierra, 252 Cal.App.2d 660, 60 Cal.Rptr. 708 (1967); Reyher v. Mayne, 90 Colo. 586, 10 P.2d 1109 (1932); Benson v. Ross, 143 Mich. 452, 106 N.W. 1120 (1906); Oliver v. Miles, 144 Miss. 852, 110 So. 666 (1927); Kuhn v. Bader, 89 Ohio App. 203, 101 N.E.2d 322 (1951).1

Our court has cited section 876 of the Restatement (First) of Torts in the context [147]*147of intentional torts. Boyle v. Anderson Fire Fighters Ass’n,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sarah L. Shake v. State of Indiana
Indiana Court of Appeals, 2025
Charles Force v. New China Hy Buffet, LLC
Indiana Court of Appeals, 2023
Willie Moore v. State of Indiana
49 N.E.3d 1095 (Indiana Court of Appeals, 2016)
Abrams v. McGuirewoods, LLP
518 B.R. 491 (N.D. Indiana, 2014)
Tracy Rambo v. Jeffrey Justice, M.D.
Indiana Court of Appeals, 2014
Keith v. Ames
295 F. App'x 309 (Tenth Circuit, 2008)
Pinkney v. Thomas
583 F. Supp. 2d 970 (N.D. Indiana, 2008)
Kovach v. Alpharma, Inc.
890 N.E.2d 55 (Indiana Court of Appeals, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
853 N.E.2d 143, 2006 Ind. App. LEXIS 1719, 2006 WL 2457410, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hellums-v-raber-indctapp-2006.