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Muckler v. Buchl

Supreme Court of Minnesota
150 N.W.2d 689 (Minn. 1967)



Joseph Buchl (defendant) owned an apartment building where Paul Muckler (plaintiff) and his 55-year-old wife had lived for seven years. Muckler’s wife fell as she descended the stairs from the second floor to the first floor in a poorly lit stairwell in the apartment building. There was no evidence of a defect in the stairs or evidence that Muckler’s wife had been drinking alcohol or suffering from any adverse medical condition. As a result of the fall, Muckler’s wife broke her hip and died four months later. Muckler filed a wrongful-death action against Buchl. At trial, a witness testified that she had visited Muckler’s wife on the day of the accident and was descending the stairs directly ahead of Muckler’s wife at the time of the incident. The witness testified that the stairwell was very dark and that the witness had to hold onto the handrail to guide her own movements down the stairs. The jury found that while there was no evidence that the inadequate lighting directly caused Muckler’s wife to fall, the preponderance of the evidence suggested a causal relationship between the insufficient lighting and her fall and subsequent death. The jury returned a verdict for Muckler and awarded him $17,000 in damages. Buchl appealed.

Rule of Law


Holding and Reasoning (Sheran, J.)

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