Doe v. Manheimer
Citation and Court
212 Conn. 748 (1989), Supreme Court of Connecticut
Facts
Jane Doe was sexually assaulted by a rapist who concealed himself in dense, overgrown vegetation on Manheimer’s property abutting a public sidewalk. The overgrowth provided cover that the attacker used to ambush Doe. Doe sued Manheimer, arguing that his negligent maintenance of the vegetation was a proximate cause of her assault.
Issue
Whether a property owner’s negligent maintenance of overgrown vegetation, which provided cover for a criminal assailant, was a proximate cause of the resulting assault on a pedestrian.
Holding
The court held that while the overgrown vegetation may have been a cause-in-fact of the assault, it was not a proximate cause because the criminal act of the third party was a superseding cause that broke the chain of legal causation.
Rule / Doctrine
A property owner’s negligence in maintaining conditions that provide opportunity for criminal conduct by third parties does not establish proximate causation where the independent criminal act of the third party is a superseding intervening cause. Liability for third-party criminal acts requires a more direct causal link or a special relationship creating a duty to protect against such acts.
Significance
Doe v. Manheimer is a key proximate cause case illustrating the limits of landowner liability when third-party criminal conduct intervenes. It is often used to explore the distinction between cause-in-fact and proximate cause, and the circumstances under which intervening criminal acts break the chain of causation.