Brown v. Collins

Brief Fact Summary. Collins (Defendant) unintentionally and without fault entered and damaged Brown (Plaintiff) land when his horses became frightened. Plaintiff sued Defendant for trespass.

Synopsis of Rule of Law. The distinction made between natural and unnatural use of land is not established in the law. The rule in Rylands v. Fletcher would impose penalty upon efforts made in a reasonable, skillful, and careful manner.

Facts. Defendant was waiting by a railroad crossing on his wagon, which was loaded with grain and drawn by two horses. An engine on the railroad frightened the horses and Defendant’s horses became unmanageable. The horses ran and struck a stone post with a street lamp owned by Plaintiff. The Defendant used ordinary care and skill in managing the horses. Plaintiff sued Defendant for trespass.

Issue. Is Defendant liable to Plaintiff for the unintentional damage done to Plaintiff’s land?

Held. No. Judgment for Defendant.
* The rule in Rylands v. Fletcher is in conflict with the rule in a class of cases, which dealt with damage resulting from neighbors’ fires. Fire, like water or steam, is likely to produce mischief if it escapes. Yet it has never been held that one person with a fire upon his land can be made liable if it escapes upon his neighbor’s land and does him damage without proof of negligence.
* Everything that a man can bring onto his land is capable of escaping against his will and without his fault.
* The distinction made between a natural and unnatural use of the land is not established in the law.

Discussion. In this case the court abandons the rule in Rylands v. Fletcher. The court found that the effect of the rule in Rylands v. Fletcher was to impose a penalty upon a person’s effort, which was made in a reasonable, skillful, and careful manner. This case holds that a person is only liable for damage to neighboring property, which is caused by his negligence. For example, a person who has a fire on his land, which escapes to his neighbors’ land, is not liable unless his negligence caused the damage.