In the case of Larrimore v. American National Insurance Co. (184 Okla. 614, 89 P.2d 340 (1939)), a guy placed a package of rat poison on the counter at a coffeeshop. Larrimore turned on a coffee burner and the rat poison exploded. Larrimore sued on the grounds that since it was illegal to “lay out poisons” in a place where people were eating, the guy was negligent.
- However, the Oklahoma Supreme Court came to the conclusion that the Statute was designed to protect people from being poisoned, not to protect people from explosions. Therefore, similar to the holding in The Polemis Case (3 K.B. 560 (1921)), the negligence wasn’t connected to the actual damage, so there isn’t enough to sustain proximate cause.
- The idea that rat poison would explode is not foreseeable and therefore outside the scope of duty.