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SCOGGINS v. WAL-MART STORES3/26/1997
This further review of our Iowa Court of Appeals decision involves the claim by Dionne M. Scoggins, as administrator of the estate of Chad J. Schleicher, that defendant, Wal-Mart Stores, Inc., is legally responsible for the death of Chad Schleicher. The district court directed a verdict for defendant; the court of appeals affirmed. We affirm the decision of the court of appeals and the judgment of the district court.
I. Facts and Procedural Background
On March 6, 1993, twenty-year-old Chad Schleicher shot himself with a gun owned by his girlfriend and loaded with ammunition he had purchased earlier that day from a Wal-Mart store in Waterloo. The suicide occurred after Schleicher had an argument with his fiancee, Lisa Van Dorn, during which Chad assaulted her and left her residence in his car. Van Dorn called police and reported the assault. She gave police a description of the vehicle Chad was driving and indicated that he carried a handgun underneath the driver's seat. Waterloo police soon located Chad's vehicle and followed him to his grandmother's driveway. After the officers exited their cars and took protective cover with their guns drawn, they heard a gun shot. An investigating officer approached the vehicle to find Chad's head bleeding and a gun in his lap. Chad died the following day as the result of the self-inflicted gunshot wound.
The administrator of Chad's estate, appellant Dionne Scoggins, filed suit against Wal-Mart alleging it negligently sold ammunition to a minor and that this negligence was a proximate cause of Chad's suicide. The matter proceeded to a jury trial. Wal-Mart stipulated that it sold the ammunition to Chad and the court took judicial notice of 18 U.S.C. ยง 922 (1991), which prohibits the sale of ammunition to persons under the age of twenty-one. At the close of all the evidence, the court granted Wal-Mart's motion for a directed verdict. The court found the estate failed to prove that Wal-Mart's alleged negligence in selling the ammunition to a minor was a proximate cause of Chad's suicide. It also found, as a matter of law, that Chad's intentional act of suicide was a superseding cause of death.
Plaintiff appealed the order and the Iowa Court of Appeals, sitting en banc, affirmed the ruling of the district court. The court found, with two judges dissenting, that there was insufficient evidence establishing proximate cause because Chad's suicide was not foreseeable. The court also found that the suicide was a superseding cause, thus relieving Wal-Mart of liability. Scoggins sought and we granted further review of the court of appeals decision.
II. Standard of Review
We review a trial court's grant of a motion for directed verdict for correction of errors of law. Iowa R. App. P. 4; Lawrence v. Grinde, 534 N.W.2d 414, 418 (Iowa 1995). We view the evidence in the light most favorable to the nonmoving party and afford the nonmovant every legitimate inference that we can reasonably deduce from the evidence. Iowa R. App. P. 14(f)(2); Lawrence, 534 N.W.2d at 418. We must determine whether reasonable minds could differ on the issue presented, and if such is the case, a jury question exists and the grant of directed verdict was inappropriate. Lawrence, 534 N.W.2d at 418.
III. Issues on Appeal
A. Proximate Cause
Although questions of negligence and proximate cause are ordinarily for the jury to decide, they may be decided as matters of law in exceptional cases. Iowa R. App. P. 14(f)(10); Ruden v. Jenk, 543 N.W.2d 605, 607 (Iowa 1996); Beeman v. Manville Corp. Asbestos Disease Comp. Fund, 496 N.W.2d 247, 254 (Iowa 1993).
We recently reviewed the development of
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