Facts
- George W. Hammerstein, about seventy years old and diabetic, checked into the Nevada Landing Hotel & Casino as an invited guest with his wife on December 30, 1989.
- He was assigned a fourth-floor room; he claimed he informed the desk clerk that his condition made stair use medically inadvisable and that he relied on assurances that an elevator would be available.
- Nevada Landing disputed that Hammerstein disclosed a medical limitation and asserted he chose the fourth-floor room after learning no main-floor rooms were available.
- Around 1:20–1:30 a.m. on January 1, 1990, the hotel’s fire alarm sounded and guests evacuated.
- The elevators automatically shut down during the alarm under applicable fire/building codes, forcing Hammerstein to descend four flights of steep metal stairs.
- During the descent, Hammerstein slipped and twisted his ankle.
- The alarm was later determined to be false; evidence showed the alarm system had activated at least eleven times in the prior three months.
- A blister formed on Hammerstein’s injured foot, later ulcerated, became gangrenous, and led to severe medical complications.
Issues
- Whether a hotel may be found negligent for failing to maintain and manage a fire alarm system and related evacuation conditions when it had notice of repeated false alarms.
- Whether injury during an evacuation down stairwells is a foreseeable result of repeated false alarms sufficient to allow a jury to find proximate cause.
- Whether the plaintiff’s preexisting diabetes and resulting complications, and any comparative fault in his response to the alarm, were jury questions that precluded summary judgment.
Decision
- The Supreme Court of Nevada reviewed the grant of summary judgment de novo.
- The court reversed the district court’s summary judgment for Nevada Landing and remanded.
- The court held that genuine issues of material fact existed as to whether Nevada Landing breached its duty to guests by failing to address repeated false alarms and whether that breach proximately caused Hammerstein’s injury.
Legal Principles
- An innkeeper owes invitees a duty to maintain premises, including safety-related systems and procedures, in a reasonably safe condition.
- Evidence that an alarm system repeatedly triggered false evacuations can support an inference that the innkeeper knew or should have known of a dangerous condition and failed to take reasonable corrective steps.
- Foreseeability may encompass injuries sustained while evacuating via stairwells when elevators are disabled during alarms; causation and breach ordinarily go to the jury when competing inferences are reasonable.
- A defendant may be liable for the full extent of harm when negligent conduct causes a physical injury that is worsened by a plaintiff’s preexisting condition (eggshell-plaintiff concept), leaving the extent of damages for trial.
- Summary judgment is improper where reasonable minds could differ on material facts and the evidence permits a rational factfinder to rule for the nonmoving party.
Conclusion
Because the record supported competing inferences about Nevada Landing’s notice of recurring false alarms, the reasonableness of its response, and whether the evacuation conditions foreseeably caused Hammerstein’s injury and complications, the negligence and causation questions required jury resolution and summary judgment was reversed.