## Facts

- Robert Arlen Andren owned a lake cabin heated by liquid propane (LP) gas supplied from an outdoor tank to a basement space heater.
- He bought the heater used in 1982 and installed it himself; it operated for several winters without incident.
- In January 1985, Andren entered the basement and detected a strong LP gas odor that intensified as he walked further inside.
- He attempted to ventilate the basement by opening windows, but they were jammed; he planned to retrieve a screwdriver from his car.
- Before leaving the basement, Andren stopped just inside the basement door and lit a cigarette; accumulated LP gas ignited and exploded, severely burning him.
- Andren had installed over 100 LP heaters and used LP appliances throughout his life.
- He knew LP gas could explode if exposed to a spark or open flame and specifically knew not to smoke or use matches when LP gas odor was present.
- Andren sued the manufacturer of the heater’s gas control valve and the retailer, alleging a defective valve design caused gas leakage and accumulation.

## Issues

1. Whether Andren’s decision to light a cigarette despite knowing the basement contained LP gas constituted assumption of risk or fault so extreme that it barred recovery as a matter of law rather than presenting a comparative-fault question for the jury.
2. Whether Andren’s conduct was a superseding cause that broke proximate causation between any alleged product defect and his injuries, precluding liability as a matter of law.
3. Whether summary judgment was proper given the undisputed evidence of Andren’s knowledge of the risk and the voluntariness of his conduct.

## Decision

- The Minnesota Court of Appeals affirmed summary judgment for the manufacturer and retailer.
- The court held that, on undisputed facts, Andren knowingly and voluntarily confronted an obvious, specific danger by introducing an ignition source into a gas-filled area he knew was hazardous.
- The court concluded Andren’s conduct barred recovery as a matter of law under assumption-of-risk/comparative-fault principles.
- The court also held Andren’s deliberate ignition of a cigarette in the circumstances constituted a superseding cause, cutting off liability for any alleged defect in the gas control valve.
- Because reasonable minds could not differ on the legal effect of Andren’s undisputed knowledge and actions, no jury question remained.

## Legal Principles

- In Minnesota, a plaintiff’s voluntary encounter with a known, specific, and appreciated danger may bar recovery as a matter of law when the conduct goes beyond ordinary negligence.
- Comparative fault generally presents a jury question, but courts may decide the issue on summary judgment when material facts are undisputed and reasonable minds cannot differ.
- An intervening act may be a superseding cause when it is not reasonably foreseeable in the legally relevant sense and breaks the causal chain from the defendant’s alleged fault.
- In product-liability cases, foreseeable misuse does not necessarily defeat causation, but deliberate, highly reckless misuse by a knowledgeable user may constitute a superseding cause.

## Conclusion

The court affirmed summary judgment because Andren, despite extensive LP-gas experience and actual knowledge of the explosion risk, chose to light a cigarette in a basement he knew contained LP gas; that conduct barred recovery and independently broke proximate causation as a superseding cause.


Andren v. White-Rodgers Co., 465 N.W.2d 102 (Minn. Ct. App. 1991)