Stone v. Williams, 64 N.Y.2d 642 (1984)
A business owner’s duty to maintain a safe premises does not extend to injuries caused by a sudden, unforeseen malfunction of a customer’s vehicle where the business’s negligence, if any, is too attenuated from the ultimate injury.
Summary
Robert Stone was injured at a Merit gas station when struck by a car driven by Kerry Williams. Williams’ car lurched backward due to a stuck accelerator pedal. Stone sued Williams, the car’s owner (Stevens), and Merit. The jury found Williams/Stevens 80% liable and Merit 20% liable. The Appellate Division reversed the judgment against Merit, finding no duty was breached, and any negligence was not the proximate cause of Stone’s injuries. The Court of Appeals affirmed, holding that the malfunction of Williams’ accelerator was the proximate cause of the injury, and any negligence by Merit was too attenuated to establish liability.
Facts
Robert Stone was getting gas at a busy Merit service station. After filling his tank, he checked the gas cap at the rear of his car. Kerry Williams pulled into the station intending to get gas behind Stone. Unable to reach the pump, Williams attempted a three-point turn. He then tried to back up slightly. Williams testified the accelerator pedal got stuck due to a loose floor mat, causing the car to lurch backward suddenly, striking Stone.
Procedural History
Stone and his wife sued Williams, Stevens (the car’s owner), and Merit. The trial court jury found Williams and Stevens 80% liable and Merit 20% liable, awarding Stone $200,000 and his wife $5,000. The Appellate Division reversed as to Merit, holding Merit owed no duty and that the accident was caused by the accelerator malfunction. Williams, Stevens, and the Stones appealed to the Court of Appeals.
Issue(s)
Whether Merit had a duty to control the movement of automobiles on its premises to prevent injuries to patrons.
Whether any breach of such a duty by Merit was the proximate cause of Stone’s injuries, considering the intervening malfunction of Williams’ accelerator pedal.
Holding
No, even if such a duty existed (which the court did not decide), because the malfunction of Williams’ accelerator pedal was the proximate cause of Stone’s injuries, and any negligence by Merit was too attenuated.
Court’s Reasoning
The court reasoned that the accident was primarily caused by the malfunction of Williams’ accelerator pedal, an unforeseen event. It distinguished the case from Derdiarian v. Felix Contracting Corp., where a proper barricade could have prevented the injury. Here, safety measures by Merit would not have prevented the sticking accelerator. The court cited Margolin v. Friedman, where a car wash was not liable when a driver negligently stepped on the accelerator instead of the brake. The court stated, “the accident happened as a result of the driver’s failure to control his vehicle. The premises ‘merely furnished the condition or occasion for the occurrence of the event rather than [being] one of its causes’”. The court found that the location of the accident on Merit’s property alone was insufficient to establish liability. The court emphasized that the failure of the accelerator to function properly so attenuated Merit’s negligence (if any) from the ultimate injury that responsibility for the injury may not be attributed to it. The court concluded that because Merit was not liable to Stone, cross-claims for indemnification and contribution asserted against Merit by Williams and Stevens also failed.