Negligent door installation claim; Factual causation; Skinner v Square D Co; Inadmissibility of subsequent repair evidence; MRE 407

Holding that plaintiff failed to offer sufficient evidence to establish factual causation, the court affirmed summary disposition for defendant on plaintiff’s negligent door installation claim. The case arose after defendant installed a front security door on the home of nonparty-D. Days later, plaintiff’s decedent (LaShunte) fell at the threshold of the door. Her brother was nearby “and called an ambulance after LaShunte expressed experiencing hip pain.” He did not see her “fall, but LaShunte told him the door ‘fell on her foot.’” Defendant later “sent an employee to repair the door and instructed [D] how to adjust the door’s closing mechanism.” LaShunte sued, alleging defendant was negligent in installing the door, rendering it defective. On appeal, plaintiff contended that it presented sufficient evidence “to establish a reasonable inference of factual causation.” The court disagreed. While plaintiff presented evidence supporting that the door closed on LaShunte’s foot, critically, it failed “to articulate any defect or malfunction of the door that caused LaShunte’s fall and injury. While evidence was presented to establish that the door began to slam shut shortly after its installation, a jury would be left to speculate whether this was either the factual or legal cause of LaShunte’s fall. When combined with LaShunte’s preexisting conditions and symptoms, including her limp and documented loss of sensation in her feet, attribution of the cause of [her] fall and injuries to a defect of the door would be mere speculation because her other medical conditions were equally possible causes of the injuries.” The court noted that “evidence of defendant’s subsequent repair of the door” was inadmissible under MRE 407.