Brenda Snell v. Norwalk Yellow Cab, Inc.

Summary

The court held that the superseding-cause doctrine remains available when apportionment is unavailable and applies to an intervening criminally reckless act. It also held that the jury's findings that the defendant's negligence was a proximate cause of the plaintiff's injuries and that the intervening conduct was a superseding cause were legally inconsistent because a superseding cause, under Connecticut law, must eliminate the defendant's negligence as a proximate cause. The judgment was reversed and the case remanded for a new trial. Ecker, J., concurring, agreed with the result but urged simplification of the superseding-cause doctrine and cautioned against treating the majority's discussion of an earlier workers' compensation decision as controlling.