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Ingersoll v. Liberty Bank of Buffalo

Supreme Court of New York
14 N.E.2d 828 (1938)


Ingersoll (plaintiff) and her husband rented the lower apartment of a two-family home owned by Liberty Bank of Buffalo (Liberty) (defendant). A stairway leading to the basement of the home featured badly worn wooden treads, and the second step from the bottom was badly cracked. The condition of the steps was known to Liberty, but Liberty failed to make any improvements or repairs. One day, Ingersoll’s husband was carrying a 32-pound package down the stairs to the basement when he fell. A piece of the second step from the bottom had broken off, and Ingersoll’s husband claimed that something had given way in his chest. Ingersoll’s husband died a few months later. Ingersoll brought a negligence action against Liberty. At trial, Ingersoll argued that the second step had broken as her husband went down the stairs, and that his death was thus a result of Liberty’s negligence. Liberty argued that Ingersoll’s husband had fainted on the steps and dropped the package, which then broke the step. A jury returned a verdict in favor of Ingersoll, but the court of appeals overturned the verdict, holding that Ingersoll had failed to prove a causal connection between her husband’s injuries and Liberty’s negligence. Ingersoll appealed.

Rule of Law


Holding and Reasoning (Finch, J.)

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