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plaintiffdefendantdamagesnegligenceliabilitycorporation
plaintiffdefendantnegligenceliabilitystatuteappealtrialcorporation

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Steagall v. Dot Mfg. Corp., 1 Pack 428, 223 Tenn. 428, 446 S.W.2d 515

Facts

Thomas Lee Steagall, a cook at the American Baptist Theological Seminary, suffered severe burns when he accidentally overturned a bottle of drain solvent, which was left uncapped on an upper shelf. Steagall had been warned about the corrosive nature of the solvent and had instructed his student helpers to handle it with care. He had ordered the solvent from Dot Manufacturing Corporation, which sold it in plastic quart bottles with labels that included warnings about its hazardous nature. The incident occurred when Steagall reached for a can of vegetables and knocked over the uncapped bottle, spilling its contents on himself.

Plaintiff, Thomas Lee Steagall, a cook employed by American Baptist Theological Seminary to prepare meals for the school cafeteria, suffered severe burns to the upper portions of his body when he accidentally turned over a bottle of drain solvent which had been left uncapped on an upper shelf.

Issue

Whether the negligence of the kitchen helper, who left the bottle uncapped, constituted an intervening cause that absolved the solvent manufacturer from liability for Steagall's injuries.

the helper's negligence was an intervening cause preventing recovering against solvent manufacturer even if manufacturer's omission of word ‘Danger’ from label was negligence per se;

Rule

In Tennessee, a defendant may not be held liable for injuries if an independent intervening cause breaks the causal connection between the defendant's negligence and the plaintiff's injury.

it is the settled rule in Tennessee that, even though the negligence charged is the violation of a statute or ordinance, and so would be negligence per se, no liability attaches unless it appears that there was a causal connection between this negligence and the injury, and that such negligence was the proximate cause of the injury.

Analysis

The court found that Steagall was fully aware of the dangers associated with the drain solvent and had taken steps to inform his helpers about its corrosive nature. The helper's act of leaving the bottle uncapped on an upper shelf was deemed an independent intervening cause that broke the causal chain, thus relieving Dot Manufacturing Corporation of liability. Even if the label had included the word 'Danger', Steagall's prior knowledge and the actions of his helpers were sufficient to establish that the manufacturer was not responsible for the injuries.

The uncontradicted evidence, all of it being the plaintiff's own evidence, clearly shows that plaintiff was fully advised as to the dangerously corrosive nature of the drain solvent; that with this knowledge he turned over the solvent and its use to his kitchen helpers, who were likewise aware of the dangers connected with its use, having been instructed in regard thereto by defendant, and told it was dangerous and to be kept on the floor by plaintiff; and thereafter one of these helpers or aided negligently left the bottle uncapped on an upper shelf in a dark storeroom where it could be turned over by one reaching up there for supplies.

Conclusion

The Supreme Court of Tennessee affirmed the judgment of the Circuit Court, ruling that Steagall could not recover damages from Dot Manufacturing Corporation due to the intervening negligence of his kitchen helper.

We find the judgment of the trial court to be in accord with the uncontradicted, plain facts and the law, so the Appeals Court judgment is set aside and the judgment of the Circuit Court, dismissing plaintiff's suit, is affirmed.

Who won?

Dot Manufacturing Corporation prevailed in the case because the court determined that the negligence of the kitchen helper was an intervening cause that broke the causal connection to the manufacturer's alleged negligence.

the court determined that the negligence of the kitchen helper was an intervening cause that broke the causal chain, thus relieving Dot Manufacturing Corporation of liability.

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