Robins Dry Dock & Repair Co. v. Flint

Brief Fact Summary.

Flint (Plaintiff) chartered a steamboat that was repaired by Robins Dry Dock & Repair Co. (Defendant). Plaintiff lost profits when Defendant took two weeks to repair the boat.

Synopsis of Rule of Law.

One cannot recover lost profits from a defendant that are due to negligence by defendant against another party.

Facts.

Flint (Plaintiff) chartered a steamboat. During the steamboat’s regular cleaning, it was discovered that it needed a new propeller. The owner of the steamboat hired Robins Dry Dock & Repair Co. (Defendant) to replace the propeller. Defendant dropped the initial propeller and had to make a new one which took two extra weeks. Plaintiff lost profits during those two weeks and sued Defendant to recover them.

Issue.

Does Plaintiff have a right to recover lost profits from Defendant due to negligence against a third party?

Held.

No, the Court held Plaintiff cannot recover lost profits from Defendant. The Court reversed.

Discussion.

The Court said Defendant had no legal obligation to Plaintiff, only to the owners of the steamboat. An act of negligence to one person (the owners) does not make the Defendant liable to another because of a contract that Defendant did not know about.