Byrne v. Boadle

Brief Fact Summary.

Byrne (Plaintiff) was walking under the window of Boadle’s (Defendant’s) warehouse when a barrel of flour fell out of the window and hit him.

Synopsis of Rule of Law.

In some egregious accidents, the occurrence of the accident itself is prima facie evidence of negligence, also known as res ipsa loquitur.

Facts.

Byrne (Plaintiff) was walking outside and passed by Boadle’s (Defendant’s) warehouse. At that exact moment, a barrel of flour fell out of the warehouse window where there was machinery to lower barrels and hit Plaintiff. Though people had seen the accident happen, there was no evidence of how it occurred.

Issue.

Was the occurrence of the flour barrel falling enough to show negligence?

Held.

Yes, the Court held that the barrel of flour falling was enough, in itself, to prove negligence.

Discussion.

• The Court says there are some accidents where the fact that they occurred at all is evidence of negligence. This is known as res ipsa loquitur.
• In this case, it’s the job of the Defendant to make sure his barrels are secured and the burden should not be on the Plaintiff to show how it came to fall on him. These things just don’t happen without negligence, so the accident itself is prima facie evidence of negligence.