Beals v. Michigan
497 Mich. 363
Mich.2015Background
- Decedent William Beals, a 19‑year‑old with disabilities and an experienced swimmer, drowned at the Michigan Career and Technical Institute pool during a recreational swim; autopsy ruled accidental drowning but the underlying reason he remained submerged is unknown.
- William Harman, the sole on‑duty certified lifeguard (a state employee and student), was not at the lifeguard stand, was reportedly distracted, and did not observe Beals for about eight minutes until another student found him underwater.
- Plaintiff (Beals’s mother as personal representative) sued Harman (and the State), alleging gross negligence and pleading around governmental immunity under MCL 691.1407(2)(c).
- The trial court denied Harman’s summary disposition motion; the Court of Appeals affirmed in a split decision (majority: jury could find proximate cause; dissent: immunity applies).
- This Court reviewed whether Harman’s failure to act was “the proximate cause” (as interpreted in Robinson v Detroit to mean “the one most immediate, efficient, and direct cause”) and held that Harman’s inaction was not that proximate cause, reversing in part and directing summary disposition for Harman.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Harman’s failure to intervene was “the proximate cause” under MCL 691.1407(2)(c) | Beals’ death was preventable; Harman’s grossly negligent inattention/failure to rescue was the immediate cause of death | Unknown cause of prolonged submersion (not Harman); Harman’s inaction is too remote to be “the one most immediate, efficient, and direct cause,” so immunity applies | Harman’s failure to intervene was not “the proximate cause” as a matter of law; governmental immunity applies and summary disposition should be granted for Harman |
Key Cases Cited
- Robinson v. Detroit, 462 Mich 439 (interpreting “the proximate cause” in MCL 691.1407(2)(c) to mean “the one most immediate, efficient, and direct cause”)
- Dean v. Childs, 474 Mich 914 (holding firefighter’s alleged misconduct was not the proximate cause where the fire itself was the immediate cause)
- Moll v. Abbott Laboratories, 444 Mich 1 (causation principles cited in discussing proximate cause analysis)