## Facts

- John Leech lived at a La Quinta Inn for about six months while separated from his wife.
- After a family dinner and confrontation with his daughter, Leech returned to the hotel and obtained a different seventh-floor room where smoking was permitted.
- Shortly before Leech died, his adult son, James, spoke with him by phone and understood Leech to be at risk of self-harm.
- James contacted front-desk employee Linda Cotton to obtain the room number and summon help; Cotton did not immediately contact emergency services.
- Leech jumped or fell from an open window of the seventh-floor room and died.
- Leech’s surviving spouse and family sued La Quinta and Cotton for wrongful death and related claims, alleging negligent failure to prevent suicide and premises liability based on an allegedly dangerous window condition.

## Issues

1. Whether Leech’s suicide was an intervening act and the sole proximate cause of death, barring negligence claims premised on failure to prevent the suicide.
2. Whether the evidence demanded a finding that Leech committed suicide rather than accidentally falling, foreclosing accidental-fall theories.
3. Even assuming an accidental fall, whether La Quinta could be liable for premises liability without evidence that it had superior knowledge of a hazardous window condition.

## Decision

- The Court of Appeals of Georgia affirmed in part and reversed in part the trial court’s summary-judgment rulings, resulting in summary judgment for La Quinta and Cotton on the claims at issue.
- The court held that Leech’s suicide was the sole proximate cause of his death, relieving La Quinta and Cotton of liability for alleged negligence in failing to prevent it.
- The court agreed that the record demanded a finding that Leech committed suicide.
- The court further held that, even under a hypothetical accidental-fall theory, plaintiffs failed to show La Quinta had superior knowledge of any window hazard, defeating premises liability.

## Legal Principles

- In negligence actions, an adult’s suicide generally constitutes an unforeseeable intervening act that breaks the causal chain unless special circumstances apply (e.g., a custodial/special relationship or the defendant’s tortious conduct causing the mental condition leading to suicide).
- Proximate cause limits liability where the connection between the defendant’s conduct and the injury is too remote for recovery.
- Georgia premises liability requires proof that the owner had actual or constructive knowledge of the hazard and that the plaintiff lacked knowledge despite ordinary care; without the owner’s superior knowledge, recovery is barred.
- On summary judgment, once a movant points to an absence of evidence on an essential element, the nonmovant must identify specific evidence creating a genuine issue for trial.

## Conclusion

The court concluded that Leech’s death was caused by his intentional act, making suicide the sole proximate cause and defeating claims that the hotel and its employee negligently failed to prevent it; and, independently, that premises liability failed because the plaintiffs did not show La Quinta had superior knowledge of any dangerous window condition, particularly given Leech’s long-term familiarity with the premises.


La Quinta Inns, Inc. v. Leech, 289 Ga. App. 812, 658 S.E.2d 637 (Ct. App. Ga. 2008)