What Happened: A 5-year-old autistic boy living in an insect-infested Philadelphia public housing building with no working smoke detectors set fire to the bugs crawling in his family’s Christmas tree, lighting a blaze that burned down the building and killed 12 people. A resident who survived the fire sued the PHA under Section 1983 of the Civil Rights Act, a federal law that allows individuals to sue government officials for money damages for violating their constitutional rights. The resident in this case claimed that the PHA deliberately placed him in danger (thereby violating his 14^th Amendment right not to be deprived of life and property without due process) by: (a) not allowing him and his family to transfer out of their overcrowded unit; and (b) deliberately concealing that the smoke detectors in the unit weren’t working. 

Ruling: The Pennsylvania federal court ruled that the resident didn’t have a valid Section 1983 claim and dismissed the case without a trial. 

Reasoning: One of the things the resident had to prove to make out a so-called “state-created danger” claim under Section 1983 is that the harm the defendant’s actions caused was “foreseeable and fairly direct.” While the harms might have been foreseeable, court reasoned that the link between the PHA’s actions and the harms was “too far removed to satisfy the fairly direct causation requirement,” noting that: 

• The fire occurred seven months after the PHA renewed the lease on the resident’s overcrowded unit;
• The resident knew the unit was overcrowded but deliberately chose to live there; and
• There was no evidence of a “direct causal link” between the use of noncompliant smoke detectors and the harm—the contention that all residents would have been able to safely evacuate had the detectors been work was mere “theory rest[ing] on speculative assumptions,” according to the court.

• Robinson v. Phila. Hous. Auth., 2025 U.S. Dist. LEXIS 151637, 2025 LX 334387, 2025 WL 2263438