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Ryan v. New York Central R.R

    Brief Fact Summary. New York Central R.R.’s (Defendant’s) woodshed was set on fire either by carelessness or by a defect in one of its engines. Plaintiff’s house was 130 feet from the shed. It was consumed in the fire despite diligent efforts to save it.

    Synopsis of Rule of Law. Every person is liable for the consequences of his own acts. He is liable for damages for the proximate results of his own acts, but not for remote damages.

    Facts. Defendant owned a woodshed, which was set on fire either by carelessness or by a defect in one of its engines. Plaintiff’s house was 130 feet from the shed. It was consumed in the fire despite diligent efforts to save it. Plaintiff sued Defendant. Defendant moved for a nonsuit, which was granted. The nonsuit was affirmed. Plaintiff appealed.

    Issue. Is Defendant liable to Plaintiff for the damages sustained to Plaintiff’s house in a fire, which originated from Defendant’s woodshed?

    Held. No. Judgment affirmed.
    * The destruction of Plaintiff’s house was not a natural and expected result of Defendant’s fire. That Defendant’s fire should spread and other buildings be consumed is not a necessary or usual result. Plaintiff’s action for negligence cannot be sustained.
    * The damages incurred by Plaintiff are not the immediate, but the remote result of Defendant’s negligence. The immediate result was the destruction of Defendant’s own woodshed. Beyond that, it was remote.
    * A man may insure his own house, or his own furniture, but he cannot insure his neighbor’s building or furniture because he has no interest in them. Each man to some extent runs the hazard of his neighbor’s conduct.

    Discussion. The terms, proximate cause and remote cause, set boundaries for how far the court is willing to extent liability. Proximate causes and remote causes are causes in fact of the injury or damage sustained. However, the court is not willing to grant relief for a remote cause, only a proximate cause. A remote cause will essentially limit a plaintiff’s ability to collect from a defendant who caused him damage. Remote causes are not recoverable because they are far removed from the scene, link, or causal connection.


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