Vincent v. Lake Erie Transportation Co.

Brief Fact Summary.

Defendant tied its steamship to plaintiffs’ dock during a severe storm to preserve its ship. Due to the severity of the storm, the ship hit the dock constantly and caused damages to the dock. Plaintiffs sought compensation from defendant.

Synopsis of Rule of Law.

A party who damages the property of another while acting out of private necessity must compensate the property owner for the resulting damage.

Facts.

The Lake Erie Transportation Company owned the steamship Reynolds. The ship was moored to a dock owned by plaintiff where the ship’s crew was discharging cargo. When the ship was done unloading, there was a growing violently. Fearing the severity of the storm, defendant decided to stay moored to the dock. The storm was so strong that it slammed the ship against the dock and the repeated pounding damaged the dock. Plaintiffs sued defendant to recover for the damages to the dock.

Issue.

Is defendant liable for damages incurred to plaintiff’s dock while trying to preserve its steamship from a severe storm?

Held.

Yes. The Supreme Court of Minnesota affirmed trial court’s decision.

Dissent.

Justice Lewis

The dissent disagreed with the majority opinion in determining whether the pounding of the dock was inevitable.

Justice Lewis argued that since the majority assumed that the boat was lawfully in position at the time the storm broke, and the master could not, in the exercise of due care, have left that position without subjecting his vessel to the hazards of the storm, then the damage to the dock caused by the pounding of the boat should also be deemed as the result of an inevitable accident.

Discussion.

The Court first reaffirmed that the storm was too severe and defendant was being prudent for not leaving the dock. The Court also rejected plaintiffs’ argument that defendant was negligent to moor the boat at an exposed part of the dock, as the Court found that part to be a proper and commonly used place for mooring.

However, even acknowledging defendant’s prudence, the Court held that defendant was liable for damages caused to plaintiffs’ dock. Defendant claimed that it was necessary to keep the ship moored to the dock and that they should not be held liable for any damages. The Court disagreed. The Court clarified that if the ship was disabled due to the force of the storm, then defendant could attribute the damage to the act of God. But in this case, the ship was deliberately held against the dock.

This is not a case where the destruction of the property was necessary to prevent a more serious disaster. Nor is it a case where, because of the act of God, the infliction of the injury was beyond the defendant’s control. In this case, defendant prudently and deliberately moor the steamship at plaintiff’s property for the purpose of preserving its own property. Therefore, defendant should be liable for damage done to the dock for protecting its own property at the expense of plaintiffs’.