Issue

Fatal chiller explosion—unforeseeable event—lack of proximate cause

Summary

In a wrongful death action filed by decedent's estate against individual employees (defendants) in the HVAC and maintenance department of a state university, the trial court properly granted summary judgment in favor of defendants where there was no genuine issue of material fact regarding whether defendants proximately caused decedent's fatal injuries when an industrial chiller exploded. The evidence established that decedent's death was the result of an unforeseeable sequence of events, since defendants could not have reasonably foreseen that their failure to fill the chiller's tubes with antifreeze during winter maintenance would have resulted in the unit becoming pressurized and causing any harm to decedent. The chiller's pressurization was unexpected because it was not connected to electricity or water and, further, the chiller's manual and labels, even had defendants read them, did not contain any warnings about bodily danger to individuals working on a pressurized chiller.

Summary from the North Carolina Reports digest (official subject index). Read the opinion →