Andrews

Facts and Procedural Background Wagner’s homeowners’ insurance company hired Property and Casualty Surveys, Inc. (PCSI) to conduct an inspection of her single-family home for the purpose of identifying hazardous conditions at her property. Andrews, who was employed by PCSI as an independent field inspector, was assigned to perform the inspection. His job was to assess the property’s general condition, document safety issues, and identify potential risks regarding structural issues. His duties also included photographing the condition of the home and preparing a written

1 After Wagner’s death, Kurt A. Wagner was appointed as her personal representative in this action.

2 report, which would be used by the homeowners’ insurance carrier to determine renewal rates and levels of coverage. Andrews had performed thousands of inspections prior to the day of the incident. His job required him to enter unfamiliar environments where he would encounter numerous unsafe conditions. PCSI expected Andrews to use his common sense and safely perform inspections. On the date of the incident, Andrews arrived at Wagner’s residence, introduced himself, and conducted the inspection of the interior of…