Muckler v. Buchl
Supreme Court of Minnesota
150 N.W.2d 689 (Minn. 1967)
Paul Muckler's (plaintiff) 55-year-old wife fell descending a poorly lit stairwell in an apartment building owned by Joseph Buchl (defendant), breaking her hip and dying four months later; there was no evidence of a structural stair defect, alcohol use, or any adverse medical condition. A witness who had been descending the same stairs just ahead of Muckler's wife testified the stairwell was so dark she herself had to hold the handrail to guide her own steps. The jury, while acknowledging no direct evidence tied the poor lighting to the fall, found the preponderance of the evidence supported a causal link and awarded Muckler $17,000; Buchl appealed.
Whether, in a wrongful-death action based on premises liability, the plaintiff must show by a preponderance of the evidence that the death was more likely than not caused by the defendant's negligence.