Rondini v. Bunn

338 So. 3d 749 (2021)

Facts

Twenty-year-old Megan met Bunn (D), a 34-year-old man, at a pub. Megan left the pub with D and they proceeded to his house. While at D's house, Megan claimed D falsely imprisoned and sexually assaulted her. D denies Megan's claim. The police investigated. D initially told the police that Megan was not at his house that night. After consulting with his attorney, he admitted Megan was there. He also admitted they had sex, but he claimed that it was consensual. The court has determined that what occurred on the night of July 1. 2015 at D's house is a question for a jury to resolve.' Megan was treated by a therapist, who diagnosed her with post-traumatic stress disorder (PTSD) and anxiety stemming from PTSD. She resumed attending classes that fall but eventually withdrew from the University of Alabama and returned to her parents' home in Austin, Texas, where she sought additional counseling from other health-care providers who similarly concluded that she was suffering from PTSD and anxiety, as well as depression. In early 2016, Megan enrolled at SMU. She met with a local psychiatrist after moving to Dallas and eventually sought counseling from the SMU health clinic. An intake form completed on February 24, 2016, indicates that she was experiencing suicidal thoughts and had a history of PTSD, anxiety, and depression stemming from a sexual assault that had occurred the previous summer. Two days later, on February 26, 2016, Megan committed suicide. Rondini (P) sued D in the federal court, seeking relief under Alabama's wrongful-death statute, P alleged that D had unlawfully and intentionally detained and imprisoned Megan and 'forcefully and intentionally raped her.' P alleged that 'Megan's death was the direct and proximate result of those intentional and malicious actions.' D denied the allegations of false imprisonment and sexual assault. D moved to dismiss the suit because Megan's suicide was an intervening or superseding cause that broke the causal connection between his alleged wrongful actions and her death. The federal court denied the motion. About two years later, D moved for summary judgment claiming Megan's suicide was a superseding cause that defeated P's wrongful-death claim. The court held that 'a reasonable juror could conclude that D's conduct was the cause-in-fact of Megan's suicide' but that 'proximate causation is less certain.' The court certified the following question: 'Whether a decedent's suicide, which occurs several months (in this case, nearly eight months) after a defendant's intentional tort (i.e., sexual assault and/or outrage) is a superseding cause breaking the chain of causation between the intentional tort and the decedent's death?'