Friday, October 19, 2012

Le Roy Fibre Co. v. Chicago, M. & S. P. Railway case brief

Le Roy Fibre Co. v. Chicago, M. & S. P. Railway (1914)
232 U.S. 340

Procedural History
•    Plaintiff property owner brought an action against defendant railroad company to recover for destruction of his property lying adjacent to the railroad’s right of way. The Circuit Court of Appeals for the Eighth Circuit certified questions to the court concerning whether the property owner could be found contributorily negligent.

Facts
•    The negligence of the railroad was the immediate cause of the destruction of the property. The property was placed by its owner near the right of way of the railroad, but on the owner’s land. The issue was whether the latter fact constituted evidence of negligence of the owner to be submitted to the jury.
•    The court held that the rights of one man in the use of his property could not be limited by the wrongs of another. The doctrine of contributory negligence was entirely out of place. Although operation of a railroad was a legitimate use of property and other property in its vicinity may be subject to risks by it, a risk from wrongful operation was not one of them. Therefore, an owner of property was not limited in the uses of his property by its proximity to a railroad or subject to other risks than those which came from the careful operation of the road or unavoidable accident.

Rule
•    The uses by one owner of his property may not be limited by the wrongful uses of another owner.
•    A property owner’s use of his property cannot be curtailed to accommodate a neighbor’s negligence.


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