In Winstead v. Yorkshire Village, the New Jersey Appellate Division reversed the trial court’s grant of summary judgment to a landlord in a personal injury suit. Plaintiff brought suit against the landlord after she was injured by a malfunctioning automatic exterior entry door at her apartment building. The trial court determined that the malfunctioning door was not the proximate cause of Plaintiff’s injuries because Plaintiff did not have a reasonable fear of being struck by it. The appellate court disagreed and held that a genuine issue of disputed material fact precluded entry of summary judgment for the landlord.

Plaintiff was an elderly woman who walked with the assistance of a walker. She lost her balance and fell while she was trying to grab the malfunctioning door so that it would not hit her. The parties did not dispute that the door malfunctioned. The trial court granted summary judgment to the landlord because it found no proximate cause since Plaintiff could have gone through the door without touching it. Therefore, it opined that she did not have a reasonable fear of being struck by it.

In reversing the trial court, the Appellate Division recognized that the landlord had a duty of care to keep the property in a reasonably safe condition. It held that a reasonable jury could determine that the landlord breached that duty by failing to inspect and repair the malfunctioning door. Contrary to the trial court’s opinion, the court found that the jury did not need to find that Plaintiff was in fear of the door striking her to find proximate causation. Instead, it held that a reasonable jury could determine that Plaintiff lost her balance as she instinctively reached for the door as it came toward her.

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