Monday, November 11, 2013

Ryan v. New York Central Railroad case brief

Ryan v. New York Central R.R. case brief summary
35 N.Y. 210 (1866)

Plaintiff landowner appealed from a decision of the general term of the fifth district (New York), which affirmed the trial court's decision to nonsuit the landowner in his action against defendant railroad to recover for damages.


The railroad negligently caused a fire that destroyed its woodshed. The fire spread to the landowner's property 130 feet away from the shed and destroyed a building. He sued the railroad to recover for the damage to the building.


  • The court affirmed the decision to nonsuit the landowner. 
  • The court held that a person was liable in damages for the proximate results of his own acts, but not for remote damages. 
  • Under the circumstances of the case the court held that the landowner's damages were the remote result of the negligence of the railroad. 
  • The immediate result was the destruction of the railroads' own wood and sheds; beyond that, it was remote. 
  • The court held that destruction of the landowner's building 130 feet away from the source of a fire was not the ordinary and natural result of a fire.


The court affirmed the decision of the appellate court affirming the trial court's decision to nonsuit the landowner's action against the railroad.

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