Monday, October 9, 2017

Ryan v. New York Central R.R. Co. 1866

COA NY - 1866

Facts:

  • D negligently set fire to its woodshed. P's house was situated 130 feet from the shed and took fire as well. P sued D for property damage.

Procedural History:

  • Trial court dismissed P's claim.
  • Appellate court affirmed.
  • NY COA affirmed.

Issues:

  • How far should liability be extended when a D causes some damage which spreads further than the D could have reasonably foreseen?

Holding/Rule:

  • Liability for a D's negligence extends only to the immediate and foreseeable (proximate!) consequences of his actions.

Reasoning:

  • Ds can only insure their own goods; they can't take out insurance on their neighbor's goods. Thus, they shouldn't be liable for their destruction.
  • In this case, the damage was too remote and unforeseeable to be attributed to the D.

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