Background
Protector Window & Door installed a front security door at the home of Perlie Smith-Duncan on April 8, 2022. The installer provided minimal instruction and did not conduct a thorough demonstration. Within a week, the door began slamming shut. Duncan and her daughter Katrina Kyles repeatedly called defendant requesting repairs, but the company did not address the issue immediately.
On April 19, 2022, Lashunte Smith fell at the threshold of the door while entering the house. She suffered a fractured femur and other injuries. An ambulance was called after she reported hip pain. Her hospital discharge summary documented that she “tripped over the screen door,” but also revealed significant preexisting medical conditions: a left ankle injury from five days prior that prevented weight-bearing, chronic peripheral neuropathy causing pain and numbness in her feet, and medical complications from alcoholism. Lashunte died in March 2024.
Katrina Kyles, as personal representative of Lashunte’s estate, filed suit alleging defendant negligently installed the door, rendering it defective and causing her injuries. Defendant moved for summary disposition, arguing plaintiff presented only speculation about causation. The trial court granted the motion. Plaintiff appealed.
The Court’s Holding
The Michigan Court of Appeals affirmed summary disposition. Although circumstantial evidence can support causation in negligence cases, the court held that plaintiff must present substantial evidence—not mere speculation—to survive summary disposition. Here, while evidence established that the door closed on Lashunte’s foot, plaintiff failed to present any evidence specifically showing what defect in the door caused her fall and injury.
The court emphasized that under Michigan law, a plaintiff must prove that “but for” the defendant’s conduct, the injury would not have occurred. Plaintiff’s evidence was insufficient because it did not establish the door had a defect on the date of the incident or explain the causal mechanism between any defect and the fall. When Lashunte’s preexisting medical conditions were considered—particularly the ankle injury that left her unable to bear weight and caused her to limp, combined with chronic peripheral neuropathy causing loss of foot sensation—attribution of her fall to a door defect became mere speculation among equally plausible alternative causes.
The court also noted that defendant’s subsequent repair of the door’s closing mechanism was inadmissible evidence under Michigan Rule of Evidence 407, which bars evidence of remedial measures to establish negligence.
Key Takeaways
- Plaintiffs in negligence actions must present substantial evidence of causation, not conjecture or speculation, to overcome summary disposition.
- Establishing that an incident occurred near a defendant’s product or negligent conduct is insufficient without evidence of the specific defect and causal link to injury.
- Preexisting medical conditions that could equally explain injuries will defeat causation when the defendant’s specific wrongdoing is not clearly established.
- Evidence of subsequent remedial measures is inadmissible and cannot support an inference of negligence or defect.
Why It Matters
This decision illustrates the substantial evidentiary burden on plaintiffs in negligence cases involving circumstantial evidence. While proximity to an injury and a defendant’s subsequent repair efforts may suggest liability, courts require proof that connects a specific defect to the injury through more than speculation. The ruling demonstrates judicial skepticism toward causation theories that merely show an incident occurred near a product when alternative explanations—here, plaintiff’s documented medical conditions—are equally plausible.
For product liability and negligence practitioners, the decision reinforces that temporal proximity between a defect and injury is legally insufficient without evidence establishing the specific defect and its causal role. Preexisting medical conditions, particularly those affecting gait and sensation, create fertile ground for defendants to argue alternative causation at summary disposition, especially when the plaintiff’s account of the incident is not supported by direct testimony or objective evidence of the product’s condition at the time of injury.