Hoyt v. Jeffers

Brief Fact Summary.

Plaintiff’s hotel caught fire and was destroyed. Plaintiff claimed that the fire was caused by sparks emitted from the chimney of defendant’s mill and sued for defendant’s negligence.

Synopsis of Rule of Law.

When there is no direct evidence, the jury may consider circumstantial evidence to determine causation.

Facts.

Defendant owned and operated a saw mill. The mill had a chimney from which sparks were seen to escape regularly. The mill was located near a hotel owned and operated by Plaintiff. Plaintiff increased the chimney height by about 12 inch in the spring of 1870, but the chimney never had a spark arrester which is any device preventing the emission of flammable debris from combustion sources.

On August 17, 1870, plaintiff’s hotel caught fire and burned down. No one saw where the fire start nor what caused the fire, but plaintiff claimed sparks emitting from defendant’s mill through its chimney caused the fire. A large amount of testimony purporting that sparks frequently escaped from the chimney in previous occasions.

Plaintiff sued defendant for negligence, and trial court entered judgment in favor of plaintiff. Defendant appealed.

This Court affirmed trial court’s judgment.

Issue.

Was trial court correct in permitting plaintiff to testify past circumstances which tending to prove that the property was set on fire by defendant’s mill?

Held.

Yes. The Supreme Court of Michigan affirmed the judgment, which found the defendant liable for damages from the fire.

Discussion.

This Court explained that although the spark was not seen to fall on plaintiff’s property, there were abundant incidents that strongly indicate so, including how the mill operated and endangered other properties for a long time in the past.

Since there was no direct evidence in this case, the Court believed that plaintiff should have the burden to show circumstances tending to prove that the property was set on fire by defendant’s mill. In this case, plaintiff testified that the chimney had a habit of emitting sparks since 1862. Sparks of fire and burning cinders or fragments of fire were frequently and generally emitted from the chimney when the mill was running, and carried to considerable distance that were often even farther than plaintiff’s property. Those sparks were often seen falling to the ground and neighboring buildings and sidewalks while still on fire, and sometimes set fire to buildings and other wooden material they fell upon. Especially when the wind was from southwest, live sparks were frequently seen to fly from the chimney and fall around the plaintiff’s property.

Given the lack of direct evidence, the Court agreed that circumstantial evidence as to the habit of the chimney in emitting live sparks, which were accustomed, especially when the wind was in the same direction it was when the plaintiff’s buildings burned, is competent. As Justice Christiancy explained,

“I can see no sound reason why he should not be at liberty to show any circumstances fairly tending to prove, or calculated to produce a reasonable belief, that this fire originated in this way on the occasion in question. “

The Court held that admission of such evidence of circumstances should be correct, and its force should be determined by the jury.