In United States Fidelity and Guarantee Co. v. Camp, 253 Mont. 64, 831 P.2d 586 (Mont. 1992), an escapee passed out in his apartment while smoking, and then started a fire when he allowed his cigarette to fall onto the couch. That court held that "such actions and their consequences were not reasonably foreseeable and act as a supervening causes of appellant's injury, thereby absolving the respondent of liability." Id. at 590.