Pittway Corp. v. Collins arose out of a house fire that claimed the life of two children and seriously injured three more. During a power outage, the children lit a candle and then went to sleep in their bedrooms in the finished basement of a rental home. Shortly after they went to sleep, the candle started a fire. The smoke detectors did not wake the children because they did not have a backup power supply and the power outage rendered them ineffective. There were not enough exits in the home for the children to escape because the builder did not finish the basement and never intended it to serve as bedrooms. The landlords were the ones who finished the basement and they did so without obtaining mandatory permits. The injured parties named a litany of defendants, including the supervising parents, the landlords, the smoke alarm manufacturers, the home builder, the electrician and the city inspector. Only the smoke alarm manufacturer, Pittway Corporation, and the builder, Ryland Group, Inc. were parties to this appeal.

Both companies filed a Motion to Dismiss, alleging that a number of events that occurred in between the defendant’s negligence and the injury, all of which amounted to superseding causes, absolving the defendant’s of liability. The Circuit Court agreed and granted the motion.

Superseding causes are important in the field of insurance defense because they cut off liability for negligent actors. Any event that occurs in between the original tortfeasor’s actions and the ultimate harm that the injured party suffers is considered an intervening cause. However, if an intervening cause is so unusual or extraordinary that the original tortfeasor could not have anticipated or prepared for the event, then it rises to the level of a superseding cause. Since proximate cause rests on whether the original actor should have been able to foresee the harm to the injured party, a superseding cause can disrupt proximate cause. The Court of Appeals held that when examining a superseding cause, the court should look at the foreseeability of both the harm to the injured party and the intervening cause.

The Court of Appeals denied the Motion to Dismiss Pittway and Ryland because it found that reasonable minds could come to different conclusions about whether or not any of the intervening causes rose to the level of superseding causes. It noted that a Motion to Dismiss will rarely be appropriate in cases that revolve around superseding causes because superseding causes are usually a fact question for the jury. This case means that defendants and insurance companies will rarely prevail on Motions to Dismiss when they assert a superseding cause.