Vincent v. Lake Erie Transportation Co.

Brief Fact Summary.

Lake Erie Transportation Co. (Defendant) kept its boat tied to Vincent’s (Plaintiff) dock during a storm, causing damage to the dock. Plaintiff sued Defendant for the damages.

Synopsis of Rule of Law.

Where one uses and damages the property of another in the protection of one’s own property out of necessity, one is still liable for damages caused to the other’s property.

Facts.

Lake Erie Transportation Co. (Defendant) had attached their boat, Reynolds, to Vincent’s (Plaintiff) dock while unloading cargo. By the time Defendant was finished unloading, a strong storm had developed and Defendant could not get a tugboat to tow the boat away from the dock. Defendant’s crew held the ship to the dock all night, replacing the lines that held the boat there as needed. The storm threw the boat against the dock which caused damage. Plaintiff sued Defendant for the damage, and the jury awarded $500 to the Plaintiff.

Issue.

Is Defendant liable for damages to Plaintiff’s property where Defendant actively protected his own property out of necessity?

Held.

Yes, the Court held that Defendant is still liable for damages to Plaintiff’s property even though the docking was out of necessity. The Court affirmed the trial court’s denial of Defendant’s request for a new trial.

Dissent.

Justice J. Lewis

The dissent takes issue with the majority’s opinion because of the strange line it draws for liability. The majority’s opinion seems to require one to anticipate future events of nature because if Defendant had used stronger lines to tie down the boat in the first place and had not needed to replace them, Defendant would not be liable for the damage. Defendant had made a contract with Plaintiff that allowed Defendant to be docked before the storm, so the dissent sees this case as an accident that dock owners should be prepared to take responsibility for.

Discussion.

• The Court begins its analysis by stating Defendant’s crew did nothing wrong here. Their actions were expected and proper to preserve their property.
• The Court separates this case from other instances of necessity because of the deliberate nature of Defendant’s actions. Defendant used Plaintiff’s property to protect its own. The way the crew held the boat to the dock, though justified, still caused damages.
• Comparing the facts of the case to Ploof v. Putnam, the Court believes that if damage to the dock had resulted in Ploof that the plaintiff would have been liable.