## Facts

- Corrine and Samuel Juisti were guests at the Hyatt Regency Hotel in Baltimore, staying on the fourteenth floor.
- Around 5:00 a.m. on May 5, 1991, the hotel’s fire alarm sounded, prompting an evacuation.
- The Juistis descended fourteen flights of stairs; Mrs. Juisti experienced shortness of breath upon reaching the ground floor and received oxygen from the fire department, and later from the hotel in her room.
- After returning home the same day, Mrs. Juisti continued to have shortness of breath and developed chest pains; she was diagnosed the next day with a collapsed lung (pneumothorax).
- A hotel security report indicated the alarm was triggered when a maintenance crew cleaned an oven hood in the kitchen without using exhaust fans; it was undisputed the exhaust fan was not on.
- In the district court, for summary-judgment purposes, it was assumed the maintenance crew was negligent and that the hotel breached its duty of reasonable care to a hotel guest.

## Issues

1. Whether, under Maryland law, negligence that triggers a hotel fire alarm and evacuation can be found to be the proximate cause of a guest’s subsequent physical injury.
2. Whether the foreseeability component of proximate cause requires foreseeability of the specific injury (collapsed lung) or only that the harm falls within a general “field of danger” created by the negligence.
3. Whether proximate cause and foreseeability were properly decided as a matter of law on summary judgment.

## Decision

- The Fourth Circuit vacated the district court’s grant of summary judgment for Hyatt and remanded.
- The court held the district court applied an overly narrow foreseeability analysis by focusing on whether the specific injury (a collapsed lung) was foreseeable.
- Applying Maryland’s “field of danger” approach, the court concluded a reasonable jury could find that negligently causing an alarm and evacuation created a foreseeable risk of some physical injury to guests.
- The court did not decide proximate cause on the merits; it held only that the issue should not have been resolved against plaintiffs as a matter of law on this record.
- A dissent would have affirmed, viewing the causal chain and injury as too attenuated and unusual to support proximate cause.

## Legal Principles

- Under Maryland proximate-cause doctrine, foreseeability turns on whether the plaintiff’s harm falls within a general field of danger the defendant should have anticipated, not whether the precise injury was foreseeable.
- Where negligent conduct allegedly triggers conditions (such as a forced evacuation) that create a risk of physical harm, proximate cause may be satisfied even if the resulting injury is an uncommon manifestation.
- Proximate cause and foreseeability are generally questions for the factfinder, and summary judgment is improper when reasonable jurors could differ on whether the injury falls within the relevant field of danger.

## Conclusion

The Fourth Circuit held that Maryland proximate-cause foreseeability focuses on whether the alleged negligence created a general risk of harm—here, injury related to a hotel evacuation—so a jury could reasonably find causation even if a collapsed lung was not itself predictable; the grant of summary judgment for the hotel was therefore vacated and the case remanded.


Juisti v. Hyatt Hotel Corp. of Md., 94 F.3d 169 (4th Cir. 1996)