eNotes: Liability – September 2024 – Washington, DC

SIGNIFICANT CASE SUMMARIES

Washington, DC Case Summary

Mancuso v. Chapel Valley Landscape Co.
District of Columbia Court of Appeals
2024 D.C. App. LEXIS 259

Decided: July 18, 2024

Trial court properly granted summary judgment because the reconstruction of a garage broke the chain of causation in connection with a claim for lost value of a parking space.

Background

Plaintiffs were residents of a DC apartment complex, whose garage collapsed. At the time of the collapse, Plaintiffs’ vehicle was parked in the garage. Plaintiffs’ car sustained damage. Plaintiffs sued the contractors of the collapsed garage, alleging that they suffered certain damages due to the contractors’ negligence. Plaintiffs claimed several categories of damages. Relevant here was a claim for damages resulting from the reduction of their parking space in the redesigned garage. Plaintiffs contended that the reconfiguration of the parking garage after the collapse caused them to lose eight inches of width in their parking space, and that this reduced the space’s value by $15,000.

Before the Trial Court, the contractors filed a Motion for partial summary judgment. They argued that Plaintiffs failed to show that the contractors were the proximate cause of the damages for the reduced parking space. Plaintiffs contended that the redesign of their parking space was a foreseeable consequence of the contactors’ originally negligent construction. The Trial Court granted the contractors’ Motion as to this claim. Plaintiffs appealed.

Holding

The DC Court of Appeals affirmed the Trial Court’s ruling. The Court concluded that the redesign of the parking garage and the restructuring of the parking spaces were superseding causes that relieved the original contractors of liability. While Plaintiffs may have been able to establish that the contractors’ negligent construction was the cause-in-fact of the garage being reconstructed and the parking space being redesigned, they failed to show how the collapse itself proximately caused a reduction in the dimensions of their parking space. The contractors were not involved in the reconstruction or the redesign of the parking garage or Plaintiffs’ parking space. The Appellate Court held that the reconstruction of the garage was an intervening act that broke the chain of causation.

Questions about this case can be directed to Joanne Lee at (202) 945-9504 or jlee@tthlaw.com.