Williams v. Hays

Brief Fact Summary.

While transporting cargo, Defendant’s ship got stuck in a storm for about three days. Defendant’s crew felt that he was acting drunk or insane after he drank a strong malaria medicine. Defendant declined two offers from passing tugboats to tug the ship to shore resulting in the ship being wrecked. Afterwards, Defendant had no recollection of the tugboats’ offers. Plaintiffs sued Defendant for negligence. The jury found in favor of Defendant. Plaintiffs appealed.

Synopsis of Rule of Law.

An insane person is liable for his torts in the same manner that a sane person is.

Facts.

William Hays (Defendant) was the captain and part owner of a cargo ship. While transporting cargo, the ship hit a massive storm and was stuck for about three days. Defendant drank a strong malaria medicine after which, his crew felt that he was acting drunk or insane. The ship was damaged in the storm. While stuck in the storm, two separate tugboats offered to tug the boat to shore, but Defendant declined. Eventually, the ship wrecked and Defendant had no memory of the tugboats’ offers. Williams, et al. (Plaintiffs), the other owners of the ship, sued Defendant for negligence to recover for the loss of the ship.

Issue.

Whether an insane person can be guilty of negligence

Held.

Yes. The trial court’s ruling is reversed and the case is remanded. An insane person is as liable for his torts as a sane person.

Discussion.

The same reasonable person standard is applied to insane people as is applied to sane people. When a loss occurs due to negligence, the negligent person, rather than the innocent victim should be held liable for the damages.