Edwards v. Allouez Mining Co.

Brief Fact Summary.

Defendant constructed a copper-mining mill on a creek, which required large amount of sand flowed to be placed in the creek. The sand flowed in the creek would deposited in a nearby downstream tract of land. About a year later, Plaintiff purchased a downstream tract of land for the purpose of compelling Defendant to purchase the land at a large profit. Plaintiff made an offer to Defendant, which he rejected. Plaintiff brought suit to enjoin Defendant from depositing sand on his land. The trial court denied Edward’s injunction, but directed the case to the jury for a damage determination. Edwards appealed.

Synopsis of Rule of Law.

A party is legally entitled to a remedy, but not equitable relief, when another party’s improper motives serve as the former party’s lawful conduct.

Facts.

Allouez Mining Company constructed a copper-mining mill upon a creek. Part of the copper-mining process required large amounts of sand flowed be in the creek. Then, the sand flowed were deposited upon a nearby downstream tracts of land. Edwards purchased one of the downstream tracts of land about one year after Allouez built the mill. Edwards’s intent of purchasing the land was to compel Allouez to purchase the land at a large profit, not for personal use. Edwards offered to sell Allouez the land for about three to five times the amount that Edwards paid. Thereafter, Allouez refused to accept the offer. Edwards instigated this action to enjoin Allouez from depositing sand on his land. Subsequently, the trial court denied Edward’s injunction, but directed the case to a jury trial for damages determination. Edwards appealed.

Issue.

Whether a party is legally entitled to a remedy, but not equitable relief, when another party’s improper motives serve as the former party’s lawful conduct.

Held.

Yes, a party is legally entitled to a remedy, but not equitable relief, when another party’s improper motives serve as the former party’s lawful conduct.

Dissent.

The trial court improperly denied Edwards’ injunction. In this case, Edwards does not have an adequate remedy available to him at law. Further, even if the jury awards Edwards damage, Edwards will still not be able to use the land without the present encumbrances. Thus, the only proper remedy is the injunction. Also, even if Edwards purposely bought the land to compel Allouez to purchase it, it is irrelevant because ones motives behind ones lawful act should not restrict or reduce the person’s remedies.

Discussion.

A party is legally entitled to a remedy, but not equitable relief, when another party’s improper motives serve as the former party’s lawful conduct. If the party who invites the harm is the complaining party, that party is less likely to be entitled to an equitable remedy. Here, the trial court properly analyzed Edwards’s complaint and found that Edwards is entitled to a legal remedy, under the laws of nuisance, as he has not broke n the law. Nonetheless, based on the cautions courts should have when ordering an equitable remedy, Edwards is not entitled equitable damages because his motives behind the purchase of land were improper. Therefore, Edwards is not entitled to an equitable remedy, and the trial court’s judgment is affirmed.