## Facts

- Indianola High School added a new wrestling room with a ceiling installed by Betts & Beer Construction Co., Inc. and Stroh Corporation.
- On the first day of school in 1997, a ceiling angle iron had fallen, and Ron Virden, a school maintenance worker, was directed by his supervisor to reinstall it.
- Virden used a ten-foot ladder, worked in an area cluttered with gym equipment, and did not seek help to place or secure the ladder or contact the contractors.
- While bolting the angle iron into place from the top of the ladder, Virden fell and suffered severe left-leg injuries requiring multiple surgeries.
- Virden sued the contractors, alleging negligent construction (including welding/attachment) that allowed the angle iron to fall and claiming that negligence proximately caused his injuries.

## Issues

1. Whether the contractors’ alleged negligence in constructing the ceiling could, as a matter of law, be a proximate cause of Virden’s injuries from falling off a ladder while repairing the defect.
2. Whether this was an “exceptional case” where proximate cause could be resolved on summary judgment because no reasonable jury could find a sufficient causal connection.

## Decision

- The Iowa Supreme Court vacated the court of appeals’ reversal and affirmed summary judgment for the contractors.
- Even assuming the contractors’ work was negligent and was a factual “but-for” cause of Virden being on the ladder, the alleged negligence was not a proximate cause of the ladder fall as a matter of law.
- The causal link between the ceiling defect and Virden’s fall was too attenuated; the injury resulted from risks associated with Virden’s independent repair activity and ladder use.

## Legal Principles

- Proximate cause requires more than factual causation; the defendant’s negligence must substantially contribute to the injury in a way that justifies legal responsibility.
- Although proximate cause is generally a jury question, it may be decided as a matter of law in an exceptional case when, even with all reasonable inferences for the plaintiff, no reasonable jury could find the defendant’s fault was a proximate cause.
- The scope of liability is tied to the risks that make the conduct negligent; negligent ceiling construction primarily creates a risk of injury from falling parts to persons below, not a risk of a repair worker’s ladder fall occurring later during remedial work.
- An injury arising from later, independent choices and conditions (such as ladder placement and work method) may fall outside the legally cognizable causal chain from the original alleged negligence.

## Conclusion

The court held that the contractors’ alleged ceiling defect did not proximately cause Virden’s ladder-fall injuries because the harm was outside the risk that made the alleged construction negligence actionable, making summary judgment appropriate.


Virden v. Betts & Beer Constr. Co., 656 N.W.2d 805 (Iowa 2003)