Anderson v. Minneapolis, st.paul and sault ste. Marie railway (1920)
146 Minn. 430
Procedural History
• Defendants appealed a judgment of the District Court of St. Louis County (Minnesota) after a jury found them liable for damages caused by sparks coming from a locomotive engine that set a fire that spread until it reached plaintiff’s land, where it destroyed some of his property.
Facts
• Plaintiff owned property near defendant railway company’s tracks. Plaintiff sued defendant railway company and Director General of Railroads for damages caused by a fire alleged to have been caused by sparks from one of defendant’s locomotive engines that spread until it reached plaintiff’s land, where it destroyed some of his property. The fire started in a bog near plaintiff’s land and smoldered there for several months, when it flared up and burned his property shortly before it was reached by one of the great fires sweeping through the area that day. The jury returned a verdict for plaintiff.
Issue
• If one negligently sets a fire which combines with another fire of no responsible origin, WILL he be liable if his fire would have caused the damage, independent of the other fire or if his fire materially caused the damage?
Rule
• If one negligently sets a fire which combines with another fire of no responsible origin, he is liable if his fire would have caused the damage, independent of the other fire or if his fire materially caused the damage.
Application
• One who negligently sets a fire is not liable if another’s property is damaged, unless it is made to appear that the fire was a material element in the destruction of the property. If a fire set by the engine of one railroad company unites with a fire set by the engine of another company, there is joint and several liability, even though either fire would have destroyed plaintiff’s property. But if one of the fires is of unknown origin, there is no liability. Minn. Gen. Stat. § 4426 (1913) leaves no room for the application of a rule which would relieve a railroad company from liability under such circumstances.
Holding
• The state supreme court affirmed the judgment because the trial court did not abuse its discretion in allowing plaintiff to amend his complaint to conform to the proof at trial; the judge’s instructions to the jury in the absence of counsel were correct statements of law, and the trial court was not obliged to notify counsel before responding to the jury’s question.
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146 Minn. 430
Procedural History
• Defendants appealed a judgment of the District Court of St. Louis County (Minnesota) after a jury found them liable for damages caused by sparks coming from a locomotive engine that set a fire that spread until it reached plaintiff’s land, where it destroyed some of his property.
Facts
• Plaintiff owned property near defendant railway company’s tracks. Plaintiff sued defendant railway company and Director General of Railroads for damages caused by a fire alleged to have been caused by sparks from one of defendant’s locomotive engines that spread until it reached plaintiff’s land, where it destroyed some of his property. The fire started in a bog near plaintiff’s land and smoldered there for several months, when it flared up and burned his property shortly before it was reached by one of the great fires sweeping through the area that day. The jury returned a verdict for plaintiff.
Issue
• If one negligently sets a fire which combines with another fire of no responsible origin, WILL he be liable if his fire would have caused the damage, independent of the other fire or if his fire materially caused the damage?
Rule
• If one negligently sets a fire which combines with another fire of no responsible origin, he is liable if his fire would have caused the damage, independent of the other fire or if his fire materially caused the damage.
Application
• One who negligently sets a fire is not liable if another’s property is damaged, unless it is made to appear that the fire was a material element in the destruction of the property. If a fire set by the engine of one railroad company unites with a fire set by the engine of another company, there is joint and several liability, even though either fire would have destroyed plaintiff’s property. But if one of the fires is of unknown origin, there is no liability. Minn. Gen. Stat. § 4426 (1913) leaves no room for the application of a rule which would relieve a railroad company from liability under such circumstances.
Holding
• The state supreme court affirmed the judgment because the trial court did not abuse its discretion in allowing plaintiff to amend his complaint to conform to the proof at trial; the judge’s instructions to the jury in the absence of counsel were correct statements of law, and the trial court was not obliged to notify counsel before responding to the jury’s question.
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Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
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