137 Ky. 619, 126 S.W. 146 (Court of Appeals of Kentucky 1910)
Watson v. Kentucky & Indiana Bridge & R.
When a defendant's negligence creates a dangerous condition (spilled gasoline and vapors), does a third party's act of striking a match constitute a superseding cause that relieves the defendant of liability—and does the answer turn on whether the intervening act was accidental/negligent versus intentional/malicious?
A negligent actor remains liable where the general type of harm results from the foreseeable operation of the risk he created, including ignition by ordinary, accidental, or negligent acts of third persons that are reasonably to be anticipated. However, an intentional, malicious, or criminal intervening act ordinarily constitutes a superseding cause that breaks the chain of proximate causation, unless such intentional conduct itself was reasonably foreseeable. Determining whether the intervening act was of a foreseeable accidental/negligent type or an unforeseeable intentional/malicious type is a question for the jury when the evidence permits either inference.
Reversed and remanded. It was error to direct a verdict for the defendant. If the ignition was caused by an accidental or negligent act (e.g., lighting a cigar), the defendant's negligence could be the proximate cause and liability could attach; if caused by an intentional or malicious act, that act would be a superseding cause cutting off liability. The nature of the intervening act was a jury question.
Watson is a foundational authority on proximate cause and intervening/superseding causation. It operationalizes foreseeability by treating ordinary accidental ignitions as within the scope of risk created by spilling gasoline, while presuming intentional or malicious acts to be superseding unless specially foreseeable. The case also highlights the jury's role in resolving disputed facts central to proximate cause and cautions against premature judicial resolution via directed verdict. Modern formulations (including Restatement approaches) still reflect Watson's central insight: liability turns on whether the harm that occurred was among the risks that made the conduct negligent, and the character of intervening acts matters to that assessment.