Laureano v. Louzoun

165 A.D.2d 866 · Appellate Division of the Supreme Court of the State of New York · 1990

Facts

A tenant, lacking heat and hot water, attempted to boil water on her stove. While pouring boiling water from one pot to another, she banged the pots together, spilling hot water and sustaining injuries. She sued the landlord, alleging negligence for failing to provide heat and hot water.

Issue

Was the landlord's failure to provide heat and hot water the proximate cause of the tenant's injuries, given her intervening act of banging pots together?

Holding

The court affirmed the dismissal of the complaint, holding that the landlord's conduct was not the proximate cause of the tenant's injuries.

Rule

An intervening act that directly causes injuries, and is not a normal consequence expected from the defendant's conduct, can break the chain of proximate causation, even if the defendant's conduct gave rise to the situation.

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Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.