Virden v. Betts and Beer Construction Company
Iowa Supreme Court
656 N.W.2d 805 (Iowa 2003)
Betts and Beer Construction (defendant) installed a ceiling in a high school wrestling room; when an angle iron later fell from that ceiling, maintenance employee Ron Virden (plaintiff) was asked to reinstall it and, while holding it in place atop a ladder, fell off the ladder and suffered severe injuries. Virden sued Betts for negligent installation of the ceiling; the trial court granted Betts summary judgment, finding any negligence wasn't the proximate cause of Virden's injuries, the court of appeals reversed, and Betts appealed.
Whether, to be considered the proximate cause of a plaintiff's injury, a defendant's breach of its duty of care must be a substantial factor in bringing about the plaintiff's injury.