Landis v. Harristown Development Corp.

4 Pa. D. & C.4th 125, 1989 Pa. Dist. & Cnty. Dec. LEXIS 118
CourtPennsylvania Court of Common Pleas, Dauphin County
DecidedSeptember 15, 1989
Docketno. 446 S 1989
StatusPublished

This text of 4 Pa. D. & C.4th 125 (Landis v. Harristown Development Corp.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Dauphin County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Landis v. Harristown Development Corp., 4 Pa. D. & C.4th 125, 1989 Pa. Dist. & Cnty. Dec. LEXIS 118 (Pa. Super. Ct. 1989).

Opinion

SCHAFFNER, J.,

Plaintiffs, through a complaint and an amended complaint, state a claim against defendants based on negligence. Defendants each have filed preliminary objections and one of the objections is a demurrer.

The case is based on the tragic murder of plaintiffs’ decedent, Anne S. Landis, on May 18, 1988 in a construction site on Market Street, in the City of Harrisburg. The land Where the criminal act occurred was under the control of Harristown Development Corporation, and defendant H.B. Alexander & Son Inc. was the entity retained by Harristown to make the improvements on the subject site. The pleadings state that the homicide occurred within the construction site, behind a fo.ur-foot-high barricade, the gates to which were not secured, and further, it is alleged that the crime was committed [126]*126with a two-by-four piece of lumber that was obtained on the construction site.

Plaintiffs allege basically, through many paragraphs, that defendants were negligent in not providing a secure construction site, in not having it patrolled by security officers, by not having it sufficiently lighted, and by not having an eight-foot wall around it, as mandated, plaintiffs allege, by a Harrisburg City ordinance. Plaintiffs allege that defendants were fully aware that the site was a dangerous one, that the criminal element was in the area, that crimes had occurred in this area and that defendants had created an attractive nuisance and an induced environment for criminal activity to occur.

Defendants simply allege that no duty existed on the part of defendants to protect a person from the criminal acts of another.

The matter was briefed and presented at argument to the court in accordance with our local rules.

Preliminary objections in the nature of a demurrer admit as true all well and clearly pleaded material factual averments and all inferences fairly deducible therefrom. Conclusions of law and unjustified inferences are not admitted by the pleadings. Starting from this point of reference, the complaint must be examined to determine whether it sets forth a cause of action which, if proved, would entitle the party to the relief sought. Where a complaint fails to set forth a cause of action, a preliminary objection in the nature of a demurrer is properly sustained. Greenspan v. United Services Automobile Association, 324 Pa. Super. 315, 471 A.2d 856 (1984).

There are four basic requirements which must coexist for a defendant to become liable to another when the legal theory of the plaintiff is negligence:

(1) A duty or obligation recognized by the law, requiring the actor to conform to a certain standard [127]*127of conduct, for the protection of others, against unreasonable risks.

(2) The failure on the actor’s part to conform to the standard required.

(3) A reasonably close causal connection between the conduct and the resulting injury.

(4) Actual loss or damage resulting to the interests of another.1

Counsel have submitted much to us, for our consideration, relative to the duty owed by defendants, and the failure of defendants to adequately perform that duty. Little has been submitted by anyone on the issue of causation. That, to us, is the appropriate beginning point and, after consideration, the ending point to this case.

If we concede, for purposes of argument, that defendants were negligent and did fail to conform to a standard of care owed plaintiffs’ decedent on any of the bases plaintiffs suggest, we are left with the question as to whether, under Pennsylvania law, a jury could find such conduct a substantial factor in bringing about a man’s act of bludgeoning another to death in the middle of the night. The answer can only be “no.” That answer is both an intuitive one and also the one we reach after study.

The first question is whether a jury must be allowed, in any event, to consider the “cause” issue. While the “legal cause” issue is normally a jury matter, it is not always so. When the facts of a case áre not disputed, and we are assuming plaintiffs will prove the underlying factual basis of this case, and the remoteness of injury from negligence is clear, the court should make the decision that legal causátion does not exist. Liney v. Chestnut Motors Inc., 421 Pa. 26, 218 A.2d 336 (1966).

[128]*128The test usually enunciated by courts for determining when the court, not the jury, should decide the causation issue is: When reasonable minds could not differ as to the result, then the issue is not for the jury, but for the court. Alumni Association v. Sullivan, 369 Pa. Super. 596, 535 A.2d 1095 (1987); Askew by Askew v. Celler, 361 Pa. Super. 35, 521 A.2d 459 (1987).

This is probably an ingenuous rationale because the test is not really whether reasonable jurors could or could not agree, but whether a judge trying the case or appellate judges reviewing it feel so clearly that an act may not be a “legal cause” under then current negligence law that they would not give the case to a jury to consider. That is an appropriate method of resolving the matter because “proximate cause” is not a fact concept, but a legal determination of when an actor should be considered for a penalty because of injury resulting from what he did. Thus, an actor can “cause” a result, a cause in fact, and have the “cause” not be a “proximate” or “a substantial factor in bringing about victim’s harm.” Restatement (Second) of Torts §431; Ford v. Jeffries, 474 Pa. 588, 379 A.2d 111 (1977). As the Superior Court stated in Alumni Association v. Sullivan, supra:

“Even where harm to a particular plaintiff may be reasonably forseeable from the defendant’s conduct, and that conduct is the cause-in-fact of the plaintiffs harm, the law makes a determination that, at some point along the casual chain, liability will be limited. The term ‘proximate cause,’ or ‘legal cause’ is applied by courts to those considerations which limit liability, even where the fact of causation can be demonstrated. Because of convenience, public policy, or a rough sense of justice, the law arbitrarily declines to trace a series of events beyond a certain [129]*129point as no longer a ‘proximate’ or ‘legal’ consequence naturally flowing from the wrongdoer’s misconduct.”

The whole issue of legal causation is a complex one that has been developing in United States jurisprudence for a long time. See Justice Cardozo’s ppinipn in Palsgraf v. Long Island Railroad Co., 248 N.Y. 339, 162 N.E. 99 (1928). Whether or not an act or acts are legal causes of an incident are conceptual questions based on public considerations, and are certainly not measurable, calcuable, standards.

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

Related

Rodgers v. Yellow Cab Co.
147 A.2d 611 (Supreme Court of Pennsylvania, 1959)
Feld v. Merriam
485 A.2d 742 (Supreme Court of Pennsylvania, 1984)
Ford v. Jeffries
379 A.2d 111 (Supreme Court of Pennsylvania, 1977)
Chapman v. City of Philadelphia
434 A.2d 753 (Superior Court of Pennsylvania, 1981)
Liney v. Chestnut Motors, Inc.
218 A.2d 336 (Supreme Court of Pennsylvania, 1966)
Mascaro v. Youth Study Center
523 A.2d 1118 (Supreme Court of Pennsylvania, 1987)
Anderson v. Bushong Pontiac Co.
171 A.2d 771 (Supreme Court of Pennsylvania, 1961)
Askew by Askew v. Zeller
521 A.2d 459 (Supreme Court of Pennsylvania, 1987)
Glick v. Martin and Mohler, Inc.
535 A.2d 626 (Supreme Court of Pennsylvania, 1987)
Glick v. Olde Town Lancaster, Inc.
535 A.2d 621 (Supreme Court of Pennsylvania, 1987)
Alumni Ass'n, Delta Zeta Zeta of Lambda Chi Alpha Fraternity v. Sullivan
535 A.2d 1095 (Supreme Court of Pennsylvania, 1987)
Greenspan v. United Services Automobile Ass'n
471 A.2d 856 (Supreme Court of Pennsylvania, 1984)
Casey v. Geiger
499 A.2d 606 (Supreme Court of Pennsylvania, 1985)
Palsgraf v. Long Island R.R. Co.
162 N.E. 99 (New York Court of Appeals, 1928)
Vann v. Board of Education
464 A.2d 684 (Commonwealth Court of Pennsylvania, 1983)

Cite This Page — Counsel Stack

Bluebook (online)
4 Pa. D. & C.4th 125, 1989 Pa. Dist. & Cnty. Dec. LEXIS 118, Counsel Stack Legal Research, https://law.counselstack.com/opinion/landis-v-harristown-development-corp-pactcompldauphi-1989.