A federal appeals court has ruled that security company ADT and appliance maker Honeywell could not be held liable for an alarm system that failed to activate during the theft of a couple's gun ultimately used to murder the mother's son.
The U.S. Court of Appeals for the Third Circuit upheld the dismissal of Julie Heeter's lawsuit against ADT and Honeywell. Heeter claimed that the alarm system's failure to alert her of Cea Jay Chattin's break-in of her and her husband Robert Heeter's Columbia County weekend home made the companies partly responsible for the death of their son Bryan Harris.
Chattin broke into the home at 7 a.m. March 26, 2015, quickly disconnecting the ADT system by removing the Honeywell control panel. He stole several heirloom firearms from the family's collection before leaving the house, according to Third Circuit Judge Luis Felipe Restrepo's opinion.
Chattin then drove to Harris' apartment and waited outside until Harris returned from work at 8 p.m. The two talked and went inside the apartment. At 10:30 p.m., Chattin shot Harris in the face with one of the stolen rifles and arranged the scene to make Harris' death look like a suicide. His body was discovered seven days later.
Julie Heeter argued in her lawsuit that the ADT system's failure to send an automatic text message when the house was broken into was a factor in Harris' death. She also noted that the family purchased the alarm system specifically because of the threat Chattin posed to Harris, claiming Chattin had "a tortured past" and "conscious disregard for the well-being of others."
But Restrepo said that companies could not be held accountable for Chattin's actions.
"Other matters had a far greater effect on the murder of Harris than the conduct of the appellees," he wrote.
The companies' "actions here did not create a force in continuous operation up to the time of the harm," Restrepo continued. "The chain of events on the day of Harris's murder did not begin with the faulty alarm system. Rather, appellees' actions were harmless until 'acted upon by other forces for which the actor is not responsible.' Here, that other force was Chattin."
Restrepo also noted that the distance between the Heeters' home and the scene of the crime matter, as ADT was only tasked with protecting the Columbia County weekend home.
"At bottom, and notwithstanding our deep sympathy for the Heeters and all affected by the tragic loss of Bryan Harris, the causal chain here is simply too attenuated in time and distance, and too disrupted by the decisions and actions of Chattin, to justify a finding of proximate cause," Restrepo said.
David A. Yanoff of The Beasley Firm in Philadelphia represented Heeter and declined to comment, as did ADT's lawyer, Charles C. Eblen of Shook, Hardy & Bacon's Kansas City office. Honeywell's attorney, Jeannine L. Lee of Stinson Leonard Street in Minneapolis, did not respond to a request for comment.