Juisti v. Hyatt Hotel Corporation of Maryland
United States Court of Appeals for the Fourth Circuit
94 F.3d 169 (1996)
A fire alarm went off at the Hyatt Regency Hotel in Baltimore, owned by Hyatt Hotel Corporation (defendant), after a cleaning crew cleaning a kitchen oven failed to turn on the exhaust system. Corrine Juisti (plaintiff) and her husband, staying on the 14th floor, evacuated down the stairs. After reaching the ground floor, Juisti had trouble breathing and needed oxygen; she was later diagnosed with a collapsed lung. Juisti sued Hyatt for negligence, claiming its failure to run the exhaust fans caused her injury. The district court granted Hyatt summary judgment, finding Juisti hadn't shown Hyatt's negligence was the proximate cause of her collapsed lung, and Juisti appealed.
Whether, under the foreseeability standard for proximate cause in a negligence case, the relevant question is whether the defendant's negligence could reasonably be expected to cause the plaintiff some injury, rather than the specific injury actually suffered.