Q1: What area of law does Derdiarian v. Felix Contracting Corp. primarily address?
Torts
Q2: What was the central legal issue in Derdiarian v. Felix Contracting Corp.?
Does a motorist's loss of control due to an epileptic seizure (and any related negligence by the motorist or his physician) constitute a superseding cause as a matter of law that breaks the causal chain, or may a contractor still be held liable where its failure to adequately secure a roadside worksite foreseeably exposed workers to the risk of intruding vehicles?
Q3: What rule did the court apply?
In New York, a defendant's negligence is a proximate cause of an injury if it was a substantial factor in bringing about the harm. An intervening act will break the causal nexus—and become a superseding cause—only when it is extraordinary under the circumstances, not foreseeable in the normal course of events, or independent of or far removed from the defendant's conduct. Whether an intervening act is a normal or foreseeable consequence of the situation created by the defendant's negligence is generally a question for the trier of fact. A defendant is liable for harms that fall within the scope of the reasonably foreseeable risks created by its conduct; the precise manner in which the harm occurs or the exact extent of injury need not be foreseeable.
Q4: What was the court's holding?
The intervening conduct of the motorist (and any related medical negligence) did not, as a matter of law, constitute a superseding cause. It was for the jury to determine whether Felix Contracting's failure to secure the worksite was a substantial factor in causing the injury and whether the vehicle intrusion was a foreseeable risk of that negligence. The Court of Appeals upheld the jury's ability to find proximate cause against the contractor and rejected the argument that the driver's medical episode automatically severed liability.
Q5: Why is Derdiarian v. Felix Contracting Corp. significant?
Derdiarian is a leading authority on intervening and superseding causation. It teaches that proximate cause typically remains a jury issue and that defendants cannot escape liability simply because a third party's negligent or medically induced act stands between their negligence and the plaintiff's harm. For students, the case operationalizes two core ideas: (1) the substantial factor test in New York and (2) the scope-of-risk approach to foreseeability. It also offers a practical template for analyzing multi-actor accident chains and for arguing when causation should—versus should not—be decided as a matter of law.