McDaid v. Aztec West Condominium Association

Maureen McDaid (plaintiff) was a resident of the Aztec West Condominium, which was managed by the Aztec West Condominium Association (AWCA) (defendant). McDaid had cerebral palsy and walked with the aid of a walker. One day, as McDaid was existing the condominium’s elevator, the elevator doors closed on her, causing her to fall to the ground and sustain serious injuries. Four days after McDaid’s accident, a construction-code official inspected the elevator and determined that the elevator’s electric eye was malfunctioning. The electric eye is designed to prevent the elevator doors from closing on objects or persons in the doors’ path. McDaid filed a negligence action against AWCA and invoked the res ipsa loquitur negligence inference, arguing that AWCA was presumably liable because elevator doors typically do not close on passengers in the absence of negligence. AWCA moved for summary judgment, arguing that in a negligence action involving a complex instrumentality like an elevator, McDaid could not solely rely on res ipsa loquitur to establish her prima facie case and that McDaid was also required to provide affirmative proof excluding other possible causes for her injuries. The trial court granted AWCA summary judgment, holding that the res ipsa loquitur negligence inference did not apply, because an elevator could malfunction randomly in the absence of negligence. On appeal, the appellate court affirmed. McDaid appealed to the New Jersey Supreme Court.