Larson v. St. Francis Hotel

Citation83 Cal. App. 2d 210, 188 P.2d 513, 1948 Cal. App.

Brief Fact Summary. The Plaintiff, Larson (Plaintiff), was injured when an armchair thrown from a window of the Defendant, St. Francis Hotel (Defendant), struck her.

Synopsis of Rule of Law. Res Ipsa Loquitur does not apply unless the object that caused the accident is under the exclusive control of the defendant and under ordinary circumstances using ordinary care, the accident would not have happened.

Facts. The Plaintiff was walking along the sidewalk outside of the Defendant’s hotel when she was struck and knocked unconscious by an armchair. It is assumed that the armchair came from one of the hotel room windows.

Issue. Whether the doctrine of Res Ipsa Loquitur applies and Defendant is negligent.

Held. Res Ipsa Loquitur does not apply.

Discussion. For the doctrine to apply, California law requires that: (i) there was an accident; (ii) the object that caused the accident was under the exclusive control and management of the defendant and (iii) had the defendant been using ordinary care, in the course of ordinary events, the accident would not have happened.
* The doctrine can have no application when there is evidence of divided responsibility and the accident can have several causes, some of which the Defendant is not responsible for. In the case of hotel rooms and their furnishings, the hotel itself has no control over the furniture, the guests do. Furthermore, this is a case where despite the Defendant using ordinary care in the ordinary course of events, the accident would still have occurred

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