Ryan v. New York Central R.R.

Brief Fact Summary.

A fire started unintentionally by the defendant emitted sparks that caused the plaintiff’s house to catch fire and burn down.

Synopsis of Rule of Law.

For a defendant to be liable for the consequences of his negligence, those consequences must be foreseeable and the ordinary and natural result of the negligent act.

Facts.

On July 15, 1854 in Syracuse, NY, the defendant negligently set fire to their woodshed and the large quantity of wood inside it. The plaintiff’s house was located 130 feet away and caught fire from the heat and sparks emitted by the burning woodshed. The house burned down despite diligent efforts to save it.

Issue.

Is the defendant liable for the damage done to the plaintiff’s house?

Held.

No. The damage to the plaintiff’s house was not a foreseeable consequence of the defendant’s negligence. The judgement of the trial court is affirmed.

Discussion.

Tort law operates on the principle that individuals are liable for the proximate results of his own acts but not for remote damages—unforeseeable consequences of the negligent act. In this case, the damage to the plaintiff’s house was not the immediate result of the defendant’s negligence, as uncontrollable factors such as direction of wind and degree of heat contributed to the circumstance of destruction of the plaintiff’s house. Unforeseeable results of negligent conduct cannot be guarded against or prevented.