Laureano v. Louzoun
Supreme Court of New York, Appellate Division
560 N.Y.S.2d 337 (1990)
Laureano (plaintiff), a tenant in a building owned by Louzoun and others (defendants), boiled two large pots of water on her stove one cold morning and, while pouring water between them, banged the pots together, spilling boiling water on her knee and feet; she sued the landlords for negligence, alleging their failure to provide sufficient heat and hot water and to maintain the boiler properly forced her to boil water herself, and that they had at least two weeks' notice of the defective conditions. The trial court granted the defendants summary judgment on proximate cause grounds, and Laureano appealed.
Whether an intervening act occurring after a defendant's negligent act may be sufficient to break the causal connection, such that the defendant's act can no longer be said to be the proximate cause of a plaintiff's subsequent injuries.