Merhi v. Becker
Connecticut Supreme Court
325 A.2d 270 (1973)
A union local (defendant) threw an outdoor picnic with unlimited beer for around 500 guests but hired only one 60-year-old, non-police security guard. The morning of the event, the committee chairman realized more security was needed but never got it. As guests drank heavily, Richard Becker (defendant) got into two fights, including one with a committee member, but was never arrested or removed. Half an hour later, Becker drove his car into the crowd of picnickers, aiming for the person he'd fought with but instead hitting Ronald Mehri (plaintiff), injuring him. A jury found the union liable, and the union appealed, arguing it couldn't have foreseen the specific harm that occurred.
Whether, for purposes of proximate cause, the test for foreseeability is whether the injury was of the same general nature as the risk of harm created by the negligent conduct, rather than whether the precise manner or extent of the injury was foreseeable.