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Barry v. Quality Steel Products, Inc. | 820 A.2d 258 (2003)

To be negligent, a defendant must’ve breached a duty to a plaintiff, and that breach must be the cause in fact and proximate cause of the plaintiff’s harm. Sometimes, a plaintiff’s injury can have multiple causes. In Barry versus Quality Steel Products, we’ll explore how a jury analyzed multiple possible causes and whether this analysis involved superseding causes.

Neil and Diana Barry worked with Bernard and Lynn Cohade as carpenters for DeLuca Construction Company. The carpenters were working on a platform attached to a roof when the platform collapsed, injuring the carpenters. The brackets used to attach the platform to the roof were designed by Quality Steel Products and sold by Ring’s End.

Although the carpenters couldn’t remember if they personally installed that particular platform, there was evidence that another DeLuca employee installed some of the brackets using nails that were smaller than Quality Steel recommended.

The carpenters sued Quality Steel and Ring’s End for design and manufacturing defect in a Connecticut state trial court. The defendants argued that using the improper nail size was a superseding cause absolving them of liability for the injuries. The trial court granted their request that the jury be instructed on superseding cause. The jury returned a verdict for the defendants, and the court entered judgment in the defendants’ favor. The carpenters appealed to the Connecticut Appellate Court. The Connecticut Supreme Court subsequently transferred the case to itself.

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