Laureano v. Louzoun

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

Facts

A tenant, due to a lack of heat and hot water, boiled water on her stove. While pouring the boiling water, she banged the pots together, spilling the water and sustaining injuries. She sued the landlords, alleging their negligence in failing to provide heat and hot water caused her injuries.

Issue

Was the landlords' failure to provide heat and hot water the proximate cause of the tenant's injuries, which resulted from her spilling boiling water after banging pots together?

Holding

The court affirmed the summary judgment, holding that the landlords' failure to provide heat and hot water was not, as a matter of law, the proximate cause of the tenant's injuries.

Rule

An intervening act that is not the direct cause of the injuries and not normally expected to ensue from the defendant's conduct breaks the chain of proximate causation.

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Case brief last reviewed 2026-01-07. Prepared by CaseReader from the published opinion.