superseding cause doctrine (Connecticut) · Go Syfert
← Connecticut issues

superseding cause doctrine in Connecticut

27 Connecticut opinions name it 3 courts 1985–2026 2 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Barry v. Quality Steel Products, Inc.green
conn · 2003 · cited in 14 Connecticut opinions naming this issue, 2004–2026
2 sentences

2026The plaintiffs maintain that “[Juan’s] injuries, and [the] harm of the general nature suffered, were foreseeable because they are an anticipated conse- quence of defective product packaging and warehouse operations” and that “[i]t is simply not any great leap to anticipate that an unsecured product might slip from its pallet and injure someone.” The plaintiffs also maintain that, under the applicable law, any third-party negligence by Rexel “does not eliminate the defendant’s negligent conduct.”13 Preliminarily, we emphasize that, on the basis of the parties’ respective appellate briefs, there

2026The plaintiffs maintain that “[Juan’s] injuries, and [the] harm of the general nature suffered, were foreseeable because they are an anticipated conse- quence of defective product packaging and warehouse operations” and that “[i]t is simply not any great leap to anticipate that an unsecured product might slip from its pallet and injure someone.” The plaintiffs also maintain that, under the applicable law, any third-party negligence by Rexel “does not eliminate the defendant’s negligent conduct.”13 Preliminarily, we emphasize that, on the basis of the parties’ respective appellate briefs, there

414
Miranti v. Brookside Shopping Center, Inc.green
conn · 1969 · cited in 6 Connecticut opinions naming this issue, 1985–2003
2 sentences

1993In a long line of cases starting with Miranti v. Brookside Shopping Center, Inc., 159 Conn. 24 , 28 , 266 A.2d 370 (1969), our Supreme Court has adopted the standards set forth in the Restatement (Second), Torts regarding the doctrine of superseding cause.

1993In a long line of cases starting with Miranti v. Brookside Shopping Center, Inc., 159 Conn. 24 , 28 , 266 A.2d 370 (1969), our Supreme Court has adopted the standards set forth in the Restatement (Second), Torts regarding the doctrine of superseding cause.

46
Archambault v. Soneco/Northeastern, Inc.green
conn · 2008 · cited in 3 Connecticut opinions naming this issue, 2012–2019
2 sentences

2019We note that several years before we decided Sapko , in Archambault v. Soneco/Northeastern, Inc. , 287 Conn. 20 , 37, 946 A.2d 839 (2008), we rejected a nearly identical claim to that which we found persuasive in Sapko , namely, that the trial court improperly had denied the defendant's request to charge the jury on the doctrine of superseding cause, when the defendant had argued that the negligence of the plaintiff's employer was the sole proximate cause of the plaintiff's injuries.

2019We note that several years before we decided Sapko , in Archambault v. Soneco/Northeastern, Inc. , 287 Conn. 20 , 37, 946 A.2d 839 (2008), we rejected a nearly identical claim to that which we found persuasive in Sapko , namely, that the trial court improperly had denied the defendant's request to charge the jury on the doctrine of superseding cause, when the defendant had argued that the negligence of the plaintiff's employer was the sole proximate cause of the plaintiff's injuries.

23
Lombardi v. Walladgreen
· 1923 · cited in 2 Connecticut opinions naming this issue, 2019–2019
2 sentences

2019See, e.g., Lombardi v. Wallad , 98 Conn. 510 , 518, 120 A. 291 (1923) ("the intervening cause either must be a cause, whether intelligent or not, [that] so entirely supersedes the operation of the defendant's negligence that it alone, without his negligence contributing thereto in any degree, produces the injury"); Mahoney v. Beatman , 110 Conn. 184 , 205, 147 A. 762 (1929) ( Maltbie , J. , dissenting) ("the circumstances [that] intervene may be natural phenomena, or the involuntary and unlawful act of a third person, or his negligent conduct, or his voluntary but lawful act, or his voluntary

2019See, e.g., Lombardi v. Wallad , 98 Conn. 510 , 518, 120 A. 291 (1923) ("the intervening cause either must be a cause, whether intelligent or not, [that] so entirely supersedes the operation of the defendant's negligence that it alone, without his negligence contributing thereto in any degree, produces the injury"); Mahoney v. Beatman , 110 Conn. 184 , 205, 147 A. 762 (1929) ( Maltbie , J. , dissenting) ("the circumstances [that] intervene may be natural phenomena, or the involuntary and unlawful act of a third person, or his negligent conduct, or his voluntary but lawful act, or his voluntary

22
RK Constructors, Inc. v. Fusco Corp.green
conn · 1994 · cited in 2 Connecticut opinions naming this issue, 2019–2019
2 sentences

2019Keeton et al., Prosser and Keeton on the Law of Torts (5th Ed. 1984)] § 42, p. 274; see also id., § 53, p. 358.’’ RK Constructors, Inc. v. Fusco Corp., 231 Conn. 381 , 388 n.4, 650 A.2d 153 (1994). 10 We note that several years before we decided Sapko, in Archambault v. Soneco/Northeastern, Inc., 287 Conn. 20, 37 , 946 A.2d 839 (2008), we rejected a nearly identical claim to that which we found persuasive in Sapko, namely, that the trial court improperly had denied the defendant’s request to charge the jury on the doctrine of superseding cause, when the defendant had argued that the negligence

2019Keeton et al., Prosser and Keeton on the Law of Torts (5th Ed. 1984)] § 42, p. 274; see also id., § 53, p. 358.’’ RK Constructors, Inc. v. Fusco Corp., 231 Conn. 381 , 388 n.4, 650 A.2d 153 (1994). 10 We note that several years before we decided Sapko, in Archambault v. Soneco/Northeastern, Inc., 287 Conn. 20, 37 , 946 A.2d 839 (2008), we rejected a nearly identical claim to that which we found persuasive in Sapko, namely, that the trial court improperly had denied the defendant’s request to charge the jury on the doctrine of superseding cause, when the defendant had argued that the negligence

22
Levesque v. Bristol Hospital, Inc.green
conn · 2008 · cited in 2 Connecticut opinions naming this issue, 2019–2019
2 sentences

2019See, e.g., Levesque v. Bristol Hospital, Inc., 286 Conn. 234 , 243 n.12, 943 A.2d 430 (2008); Barry v. Quality Steel Products, Inc., supra, 263 Conn. 434 ; Board of Education v. St.

2019See, e.g., Levesque v. Bristol Hospital, Inc., 286 Conn. 234 , 243 n.12, 943 A.2d 430 (2008); Barry v. Quality Steel Products, Inc., supra, 263 Conn. 434 ; Board of Education v. St.

22
SAPKO v. Stategreen
conn · 2012 · cited in 2 Connecticut opinions naming this issue, 2019–2026
2 sentences

2026The plaintiffs maintain that “[Juan’s] injuries, and [the] harm of the general nature suffered, were foreseeable because they are an anticipated conse- quence of defective product packaging and warehouse operations” and that “[i]t is simply not any great leap to anticipate that an unsecured product might slip from its pallet and injure someone.” The plaintiffs also maintain that, under the applicable law, any third-party negligence by Rexel “does not eliminate the defendant’s negligent conduct.”13 Preliminarily, we emphasize that, on the basis of the parties’ respective appellate briefs, there

2026The plaintiffs maintain that “[Juan’s] injuries, and [the] harm of the general nature suffered, were foreseeable because they are an anticipated conse- quence of defective product packaging and warehouse operations” and that “[i]t is simply not any great leap to anticipate that an unsecured product might slip from its pallet and injure someone.” The plaintiffs also maintain that, under the applicable law, any third-party negligence by Rexel “does not eliminate the defendant’s negligent conduct.”13 Preliminarily, we emphasize that, on the basis of the parties’ respective appellate briefs, there

12
Snell v. Norwalk Yellow Cab, Inc.green
conn · 2019 · cited in 2 Connecticut opinions naming this issue, 2025–2026
2 sentences

2026The plaintiffs maintain that “[Juan’s] injuries, and [the] harm of the general nature suffered, were foreseeable because they are an anticipated conse- quence of defective product packaging and warehouse operations” and that “[i]t is simply not any great leap to anticipate that an unsecured product might slip from its pallet and injure someone.” The plaintiffs also maintain that, under the applicable law, any third-party negligence by Rexel “does not eliminate the defendant’s negligent conduct.”13 Preliminarily, we emphasize that, on the basis of the parties’ respective appellate briefs, there

2026The plaintiffs maintain that “[Juan’s] injuries, and [the] harm of the general nature suffered, were foreseeable because they are an anticipated conse- quence of defective product packaging and warehouse operations” and that “[i]t is simply not any great leap to anticipate that an unsecured product might slip from its pallet and injure someone.” The plaintiffs also maintain that, under the applicable law, any third-party negligence by Rexel “does not eliminate the defendant’s negligent conduct.”13 Preliminarily, we emphasize that, on the basis of the parties’ respective appellate briefs, there

12
Sullivan v. Metro-North Commuter Railroadgreen
conn · 2009 · cited in 2 Connecticut opinions naming this issue, 2017–2019
2 sentences

2019E.g., Sapko v. State , supra, 305 Conn. at 377 , 44 A.3d 827 ("the superseding cause doctrine was largely abandoned in Barry in favor of comparative and contributory negligence ... subject ... to certain narrow exceptions, namely, situations in which an unforeseeable intentional tort, force of nature or criminal event supersedes the defendant's tortious conduct" [citation omitted; internal quotation marks omitted] ); Sullivan v. Metro-North Commuter Railroad Co. , supra, 292 Conn. at 167 , 971 A.2d 676 ( Barry "specifically limited our abolishment of the doctrine to the situation in cases ...

2019E.g., Sapko v. State , supra, 305 Conn. at 377 , 44 A.3d 827 ("the superseding cause doctrine was largely abandoned in Barry in favor of comparative and contributory negligence ... subject ... to certain narrow exceptions, namely, situations in which an unforeseeable intentional tort, force of nature or criminal event supersedes the defendant's tortious conduct" [citation omitted; internal quotation marks omitted] ); Sullivan v. Metro-North Commuter Railroad Co. , supra, 292 Conn. at 167 , 971 A.2d 676 ( Barry "specifically limited our abolishment of the doctrine to the situation in cases ...

12
Durniak v. August Winter & Sons, Inc.green
conn · 1992 · cited in 1 Connecticut opinions naming this issue, 2012–2012
2 sentences

2012See, e.g., Doe v. Yale University, 252 Conn. 641, 672 , 748 A.2d 834 (2000) ("[t]he purpose of the [act] ... is to provide compensation for injuries arising out of and in the course of employment, regardless of fault" [citation omitted; internal quotation marks omitted]); see also Durniak v. August Winter & Sons, Inc., 222 Conn. 775, 782 , 610 A.2d 1277 (1992) (observing that comparative negligence statute is inapplicable to workers' compensation cases); O'Connor v. O'Connor, 201 Conn. 632, 654 , 519 A.2d 13 (1986) (workers' compensation scheme "eschews investigation into the possible negligen

2012See, e.g., Doe v. Yale University, 252 Conn. 641, 672 , 748 A.2d 834 (2000) ("[t]he purpose of the [act] ... is to provide compensation for injuries arising out of and in the course of employment, regardless of fault" [citation omitted; internal quotation marks omitted]); see also Durniak v. August Winter & Sons, Inc., 222 Conn. 775, 782 , 610 A.2d 1277 (1992) (observing that comparative negligence statute is inapplicable to workers' compensation cases); O'Connor v. O'Connor, 201 Conn. 632, 654 , 519 A.2d 13 (1986) (workers' compensation scheme "eschews investigation into the possible negligen

11
Doe v. Yale Universitygreen
conn · 2000 · cited in 1 Connecticut opinions naming this issue, 2012–2012
2 sentences

2012See, e.g., Doe v. Yale University, 252 Conn. 641, 672 , 748 A.2d 834 (2000) ("[t]he purpose of the [act] ... is to provide compensation for injuries arising out of and in the course of employment, regardless of fault" [citation omitted; internal quotation marks omitted]); see also Durniak v. August Winter & Sons, Inc., 222 Conn. 775, 782 , 610 A.2d 1277 (1992) (observing that comparative negligence statute is inapplicable to workers' compensation cases); O'Connor v. O'Connor, 201 Conn. 632, 654 , 519 A.2d 13 (1986) (workers' compensation scheme "eschews investigation into the possible negligen

2012See, e.g., Doe v. Yale University, 252 Conn. 641, 672 , 748 A.2d 834 (2000) ("[t]he purpose of the [act] ... is to provide compensation for injuries arising out of and in the course of employment, regardless of fault" [citation omitted; internal quotation marks omitted]); see also Durniak v. August Winter & Sons, Inc., 222 Conn. 775, 782 , 610 A.2d 1277 (1992) (observing that comparative negligence statute is inapplicable to workers' compensation cases); O'Connor v. O'Connor, 201 Conn. 632, 654 , 519 A.2d 13 (1986) (workers' compensation scheme "eschews investigation into the possible negligen

11
Hasychak v. Zoning Board of Appealsgreen
conn · 2010 · cited in 1 Connecticut opinions naming this issue, 2012–2012
2 sentences

2012See, e.g., Hasychak v. Zoning Board of Appeals, 296 Conn. 434 , 437 n. 4, 994 A.2d 1270 (2010). [10] General Statutes § 52-572h (b) provides in relevant part: "In causes of action based on negligence, contributory negligence shall not bar recovery in an action by any person or the person's legal representative to recover damages resulting from personal injury, wrongful death or damage to property if the negligence was not greater than the combined negligence of the person or persons against whom recovery is sought...." [11] General Statutes § 52-572o (a) provides: "In any claim under sections

2012See, e.g., Hasychak v. Zoning Board of Appeals, 296 Conn. 434 , 437 n. 4, 994 A.2d 1270 (2010). [10] General Statutes § 52-572h (b) provides in relevant part: "In causes of action based on negligence, contributory negligence shall not bar recovery in an action by any person or the person's legal representative to recover damages resulting from personal injury, wrongful death or damage to property if the negligence was not greater than the combined negligence of the person or persons against whom recovery is sought...." [11] General Statutes § 52-572o (a) provides: "In any claim under sections

11
Sapko v. Stategreen
connappct · 2010 · cited in 1 Connecticut opinions naming this issue, 2012–2012
2 sentences

2012See Sapko v. State, 123 Conn.App. 18, 26, 30 , 1 A.3d 250 (2010).

2012See Sapko v. State, 123 Conn.App. 18, 26, 30 , 1 A.3d 250 (2010).

11
DiStefano v. Milardogreen
conn · 2005 · cited in 1 Connecticut opinions naming this issue, 2006–2006
2 sentences

2006See DiStefano v. Milardo, supra, 276 Conn. at 421 , 886 A.2d 415 .

2006See DiStefano v. Milardo, supra, 276 Conn. at 421 , 886 A.2d 415 .

11
Wagner v. Clark Equipment Co.green
conn · 1997 · cited in 1 Connecticut opinions naming this issue, 1998–1998
2 sentences

1998See Wagner v. Clark Equipment Co., Inc., 243 Conn. 168 , 178 , 700 A.2d 38 (1997).

1998See Wagner v. Clark Equipment Co., Inc., 243 Conn. 168 , 178 , 700 A.2d 38 (1997).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (18)

CaseCitedYears
Virelli v. Benhattie, Inc. green
conn · 1959
2 sentences

2003Miranti v. Brookside Shopping Center, Inc., 159 Conn. 24, 29 , 266 A.2d 370 (1969); Virelli v. Benhattie, Inc., 146 Conn. 203, 209 , 148 A.2d 760 (1959).

2003Miranti v. Brookside Shopping Center, Inc., 159 Conn. 24, 29 , 266 A.2d 370 (1969); Virelli v. Benhattie, Inc., 146 Conn. 203, 209 , 148 A.2d 760 (1959).

51985–2003
Mahoney v. Beatman green
· 1929
2 sentences

2019See, e.g., Lombardi v. Wallad , 98 Conn. 510 , 518, 120 A. 291 (1923) ("the intervening cause either must be a cause, whether intelligent or not, [that] so entirely supersedes the operation of the defendant's negligence that it alone, without his negligence contributing thereto in any degree, produces the injury"); Mahoney v. Beatman , 110 Conn. 184 , 205, 147 A. 762 (1929) ( Maltbie , J. , dissenting) ("the circumstances [that] intervene may be natural phenomena, or the involuntary and unlawful act of a third person, or his negligent conduct, or his voluntary but lawful act, or his voluntary

2019See, e.g., Lombardi v. Wallad , 98 Conn. 510 , 518, 120 A. 291 (1923) ("the intervening cause either must be a cause, whether intelligent or not, [that] so entirely supersedes the operation of the defendant's negligence that it alone, without his negligence contributing thereto in any degree, produces the injury"); Mahoney v. Beatman , 110 Conn. 184 , 205, 147 A. 762 (1929) ( Maltbie , J. , dissenting) ("the circumstances [that] intervene may be natural phenomena, or the involuntary and unlawful act of a third person, or his negligent conduct, or his voluntary but lawful act, or his voluntary

22019–2019
Snell v. Norwalk Yellow Cab, Inc. green
connappct · 2017
2 sentences

2019The defendants pleaded that, '[i]f the plaintiff sustained the injuries and losses as alleged in her complaint, said injuries and losses were the result of the intentional, criminal, reckless and/or negligent conduct of a third party, which intervened to break the chain of causation between [Sainval's] alleged negligence and/or carelessness and the plaintiff's alleged injuries and losses.' " (Footnotes altered; footnote in original, footnotes omitted.) Snell v. Norwalk Yellow Cab, Inc. , supra, 172 Conn. App. at 42 -45 , 158 A.3d 787 . "[T]he court initially indicated to the parties that it wa

2019The defendants pleaded that, '[i]f the plaintiff sustained the injuries and losses as alleged in her complaint, said injuries and losses were the result of the intentional, criminal, reckless and/or negligent conduct of a third party, which intervened to break the chain of causation between [Sainval's] alleged negligence and/or carelessness and the plaintiff's alleged injuries and losses.' " (Footnotes altered; footnote in original, footnotes omitted.) Snell v. Norwalk Yellow Cab, Inc. , supra, 172 Conn. App. at 42 -45 , 158 A.3d 787 . "[T]he court initially indicated to the parties that it wa

22019–2019
D'Arcy v. Shugrue green
connappct · 1985
2 sentences

1997For instance, in D’Arcy v. Shugrue, 5 Conn. App. 12, 24-25 , 496 A.2d 967 , cert. denied, 197 Conn. 817 , 500 A.2d 1336 (1985), the Appellate Court stated in the context of a negligence action: “If the third person’s negligence is determined to be a superseding cause of the plaintiffs injury, that negligence, rather than the negligence of the party attempting to invoke the doctrine of superseding cause, is said to be the sole proximate cause of the injury.

1997For instance, in D’Arcy v. Shugrue, 5 Conn. App. 12, 24-25 , 496 A.2d 967 , cert. denied, 197 Conn. 817 , 500 A.2d 1336 (1985), the Appellate Court stated in the context of a negligence action: “If the third person’s negligence is determined to be a superseding cause of the plaintiffs injury, that negligence, rather than the negligence of the party attempting to invoke the doctrine of superseding cause, is said to be the sole proximate cause of the injury.

21993–1997
Stewart v. Federated Department Stores, Inc. green
conn · 1995
2 sentences

2019Stores, Inc. , supra, 234 Conn. at 606 , 662 A.2d 753 . "[A]lthough nearly every treatise involving the law of torts acknowledges the existence of the doctrine of superseding cause, it is defined differently by various scholars.

2019Stores, Inc. , supra, 234 Conn. at 606 , 662 A.2d 753 . "[A]lthough nearly every treatise involving the law of torts acknowledges the existence of the doctrine of superseding cause, it is defined differently by various scholars.

12019–2019
Pisel v. Stamford Hospital green
conn · 1980
2 sentences

2019Id., comment (i), p. 504 (entitled ‘‘Understanding and characterizing the risk of harm’’); see also id., § 34, comments (d) and (e), pp. 572–74. 5 See, e.g., Ruiz v. Victory Properties, LLC, 315 Conn. 320 , 323, 107 A.3d 381 (2015); Pisel v. Stamford Hospital, 180 Conn. 314, 333 , 430 A.2d 1 (1980); 2 Restatement (Second), supra, § 435 (1), p. 449; see also, e.g., Connecticut Civil Jury Instructions 3.1-4, available at http://www.jud.ct.gov/JI/civil/civ- il.pdf (last visited August 5, 2019) (entitled ‘‘Proximate Cause—Foresee- able Risk’’). 6 In Barry v. Quality Steel Products, Inc., 263 Conn.

2019Id., comment (i), p. 504 (entitled ‘‘Understanding and characterizing the risk of harm’’); see also id., § 34, comments (d) and (e), pp. 572–74. 5 See, e.g., Ruiz v. Victory Properties, LLC, 315 Conn. 320 , 323, 107 A.3d 381 (2015); Pisel v. Stamford Hospital, 180 Conn. 314, 333 , 430 A.2d 1 (1980); 2 Restatement (Second), supra, § 435 (1), p. 449; see also, e.g., Connecticut Civil Jury Instructions 3.1-4, available at http://www.jud.ct.gov/JI/civil/civ- il.pdf (last visited August 5, 2019) (entitled ‘‘Proximate Cause—Foresee- able Risk’’). 6 In Barry v. Quality Steel Products, Inc., 263 Conn.

12019–2019
O'Connor v. O'Connor green
conn · 1986
2 sentences

2012See, e.g., Doe v. Yale University, 252 Conn. 641, 672 , 748 A.2d 834 (2000) ("[t]he purpose of the [act] ... is to provide compensation for injuries arising out of and in the course of employment, regardless of fault" [citation omitted; internal quotation marks omitted]); see also Durniak v. August Winter & Sons, Inc., 222 Conn. 775, 782 , 610 A.2d 1277 (1992) (observing that comparative negligence statute is inapplicable to workers' compensation cases); O'Connor v. O'Connor, 201 Conn. 632, 654 , 519 A.2d 13 (1986) (workers' compensation scheme "eschews investigation into the possible negligen

2012See, e.g., Doe v. Yale University, 252 Conn. 641, 672 , 748 A.2d 834 (2000) ("[t]he purpose of the [act] ... is to provide compensation for injuries arising out of and in the course of employment, regardless of fault" [citation omitted; internal quotation marks omitted]); see also Durniak v. August Winter & Sons, Inc., 222 Conn. 775, 782 , 610 A.2d 1277 (1992) (observing that comparative negligence statute is inapplicable to workers' compensation cases); O'Connor v. O'Connor, 201 Conn. 632, 654 , 519 A.2d 13 (1986) (workers' compensation scheme "eschews investigation into the possible negligen

12012–2012
Monk v. Temple George Associates, LLC green
conn · 2005
2 sentences

2012The ultimate test of the existence of the duty to use care is found in the foreseeability that harm may result if it is not exercised. . . . [In other words], would the ordinary [person] in the defendant's position, knowing what he knew or should have known, anticipate that harm of the general nature of that suffered was likely to result?" (Citation omitted; internal quotation marks omitted.) Monk v. Temple George Associates, LLC, 273 Conn. 108, 114-15 , 869 A.2d 179 (2005). [3] The trial court, in discussing the ramifications of extending a duty of care to the defendant under the circumstance

2012The ultimate test of the existence of the duty to use care is found in the foreseeability that harm may result if it is not exercised. . . . [In other words], would the ordinary [person] in the defendant's position, knowing what he knew or should have known, anticipate that harm of the general nature of that suffered was likely to result?" (Citation omitted; internal quotation marks omitted.) Monk v. Temple George Associates, LLC, 273 Conn. 108, 114-15 , 869 A.2d 179 (2005). [3] The trial court, in discussing the ramifications of extending a duty of care to the defendant under the circumstance

12012–2012
Birnie v. Electric Boat Corp. green
conn · 2008
2 sentences

2012First, the plaintiff contends that, although the Appellate Court properly concluded that the superseding cause doctrine does not apply to cases arising under the act, the Appellate Court was incorrect in determining that the contrary conclusion of the board and the commissioner constituted harmless error. [7] Second, the plaintiff contends that the Appellate Court improperly failed to heed this court's statement in Birnie v. Electric Boat Corp., supra, 288 Conn. 392 , 953 A.2d 28 , that "the substantial factor causation standard simply requires that the employment, or the risks incidental ther

2012First, the plaintiff contends that, although the Appellate Court properly concluded that the superseding cause doctrine does not apply to cases arising under the act, the Appellate Court was incorrect in determining that the contrary conclusion of the board and the commissioner constituted harmless error. [7] Second, the plaintiff contends that the Appellate Court improperly failed to heed this court's statement in Birnie v. Electric Boat Corp., supra, 288 Conn. 392 , 953 A.2d 28 , that "the substantial factor causation standard simply requires that the employment, or the risks incidental ther

12012–2012
Sullivan v. Metro-North Commuter Railroad green
connappct · 2006
2 sentences

2009The majority of the Appellate Court concluded that the trial court did not abuse its discretion when it precluded the testimony of the plaintiff's expert witness and that the trial court properly instructed the jury on the superseding cause doctrine because that doctrine is still valid in Connecticut. [3] *680 Id., at 745, 751 , 901 A.2d 1258 .

2009Id., at 751, 901 A.2d 1258 .

12009–2009
Torres v. El Paso Electric Co. green
nm · 1999
2 sentences

2003Additionally, with respect to cases in which the superseding cause doctrine is used by defendants to attempt to shift their fault to other intervening tortfeasors, the New Mexico Supreme Court concluded that a jury instruction based on superseding cause would “unduly emphasize the conduct of one tortfeasor over another and would potentially conflict with the jury’s duty to apportion fault.” Id., 737 .

2003Id., 739 .

12003–2003
Control Techniques, Inc. v. Johnson green
ind · 2002
2 sentences

2003In Control Techniques, Inc. v. Johnson, 762 N.E.2d 104 (Ind. 2002), the Indiana Supreme Court analyzed the relationship between that state’s comparative fault act and the doctrine of superseding cause.

2003Id., 108 .

12003–2003
Exxon Co., USA v. Sofec, Inc. green
scotus · 1996
1 sentence

1998However, "[t]he doctrine of superseding cause is . . . applied where the defendant's negligence in fact substantially contributed to the plaintiff's injury, but the injury was actually brought about by a later cause of independent origin that was not foreseeable." Id. , 1818.

11998–1998
Purcell v. Slagle green
conn · 1985
11997–1997
Wesson v. City of Milford green
conn · 1985
1 sentence

1997For instance, in D’Arcy v. Shugrue, 5 Conn. App. 12, 24-25 , 496 A.2d 967 , cert. denied, 197 Conn. 817 , 500 A.2d 1336 (1985), the Appellate Court stated in the context of a negligence action: “If the third person’s negligence is determined to be a superseding cause of the plaintiffs injury, that negligence, rather than the negligence of the party attempting to invoke the doctrine of superseding cause, is said to be the sole proximate cause of the injury.

11997–1997
Corey v. Phillips green
conn · 1939
2 sentences

1997Virelli v. Benhattie, Inc., 146 Conn. 203, 209 , 148 A.2d 760 (1959); see also Miranti v. Brookside Shopping Center, Inc., 159 Conn. 24, 29 , 266 A.2d 370 (1969); Corey v. Phillips, [ 126 Conn. 246, 254-56 , 10 A.2d 370 (1939)].” Thus, a manufacturer’s liability is limited only if the subsequent alteration or modification breaks the chain of causation, akin to an intervening superseding cause in negligence law.

1997Virelli v. Benhattie, Inc., 146 Conn. 203, 209 , 148 A.2d 760 (1959); see also Miranti v. Brookside Shopping Center, Inc., 159 Conn. 24, 29 , 266 A.2d 370 (1969); Corey v. Phillips, [ 126 Conn. 246, 254-56 , 10 A.2d 370 (1939)].” Thus, a manufacturer’s liability is limited only if the subsequent alteration or modification breaks the chain of causation, akin to an intervening superseding cause in negligence law.

11997–1997
Burns v. Gleason Plant Security, Inc. green
connappct · 1987
11996–1996
Merhi v. Becker green
conn · 1973
11993–1993

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 52-572h (12) CT § Conn. Gen. Stat. § 51-199 (7) CT § Conn. Gen. Stat. § 52-572o (7) CT § Conn. Gen. Stat. § 31-284 (4) CT § Conn. Gen. Stat. § 31-275 (3) CT § Conn. Gen. Stat. § 52-572 (3) CT § Conn. Gen. Stat. § 52-572m (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CT 27 (1985–2026) WA 12 (1980–2023) MD 10 (1975–2019) CA 9 (1976–2024) MS 8 (2002–2016) MN 6 (1982–2024) IN 6 (2002–2025) AZ 6 (2009–2022) TN 4 (2006–2019) WI 4 (1978–1999) MI 3 (2016–2023) TX 3 (2018–2021) IA 3 (1995–1999) KY 3 (2007–2025) NY 3 (2013–2013) VA 2 (2024–2025) UT 2 (2018–2024) GA 2 (1956–1956)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check