## Facts

- Kathleen Delaney lived with John M. Reynolds, a police officer, in Reynolds’s house beginning in mid-1998.
- Reynolds regularly kept a handgun loaded and unsecured in his bedroom, stored in a duffle bag or bureau drawer, without a trigger lock.
- Reynolds knew Delaney knew where the gun was kept.
- Reynolds was aware Delaney was in ongoing treatment for substance abuse and depression and that her condition had recently worsened due to medication changes.
- Delaney presented evidence that she told Reynolds about prior suicidal behavior and expressed suicidal thoughts; Reynolds denied knowledge of any prior attempts or such statements.
- Delaney also claimed that on one occasion Reynolds handed her a gun and told her to go outside so she would not make a mess in the house; she did not shoot herself and was later told the gun was unloaded.
- On May 7–8, 1999, Delaney left intending to attend an Alcoholics Anonymous meeting but instead used crack cocaine and consumed alcohol.
- After returning home and drinking more alcohol, Delaney asserted Reynolds told her to move out; while packing, she retrieved the handgun.
- Delaney claimed she twice pulled the trigger while aiming the gun at Reynolds, but it did not fire; she then ran upstairs and fired the gun under her chin, causing severe injuries.
- Delaney contended she believed the gun was unloaded and did not intend to kill or seriously injure herself when she pulled the trigger.
- Delaney sued Reynolds for negligence, alleging he unreasonably kept a loaded handgun readily accessible despite knowledge of her serious emotional problems and suicidal ideation.

## Issues

1. Whether Delaney’s self-inflicted gunshot wound was, as a matter of law, an independent, superseding cause that severed proximate causation for Reynolds’s alleged negligent firearm storage.
2. Whether disputed facts concerning Reynolds’s knowledge of Delaney’s mental health and suicidal ideation made self-inflicted harm reasonably foreseeable.
3. Whether disputed facts concerning Delaney’s intent—particularly her asserted belief that the gun was unloaded—precluded summary judgment on causation.

## Decision

- The Appeals Court of Massachusetts reversed the Superior Court’s grant of summary judgment for Reynolds.
- The court held Massachusetts law does not impose a categorical rule that suicide or self-inflicted injury is always a superseding cause.
- The court concluded material factual disputes existed regarding (i) the foreseeability of self-inflicted harm in light of Reynolds’s alleged knowledge and conduct and (ii) whether Delaney intended serious injury or death.
- The case was remanded for further proceedings.

## Legal Principles

- In Massachusetts negligence law, self-inflicted injury (including suicide) is not automatically an intervening, superseding cause; proximate cause turns on foreseeability and the scope of risk created by the defendant’s conduct.
- When a defendant knows or has reason to know of a plaintiff’s mental instability and suicidal ideation, negligent conduct that makes a lethal instrument readily accessible can create a foreseeable risk of self-harm.
- At summary judgment, courts must draw reasonable inferences in favor of the nonmoving party; where intent and foreseeability depend on disputed evidence, causation is generally for the factfinder.
- A plaintiff’s asserted belief that a gun was unloaded can create a triable issue on whether the act was intended to cause serious injury or death, affecting superseding-cause analysis.

## Conclusion

Summary judgment was improper because the record permitted a factfinder to conclude that Reynolds’s alleged negligent storage of a loaded, accessible firearm created a foreseeable risk of self-inflicted harm and because Delaney’s intent when she pulled the trigger—particularly her claimed belief that the gun was unloaded—remained genuinely disputed.


Delaney v. Reynolds, 63 Mass. App. Ct. 239, 825 N.E.2d 554 (2005)