Ryan v. New York Central R.R. Co. – Case Brief
Ryan v. New York Central R.R. Co., Ct. of App. of N.Y., 35 N.Y. 210, 91 Am. Dec. 49 (1866).
Facts: New York Central Railroad (D) negligently set fire to its woodshed. The fire spread and destroyed a number of buildings including Ryan’s (P) house 130 feet away – Ryan sued. The trial court entered a nonsuit and the appellate court affirmed. Ryan appealed.
Issue: When a party’s acts result in damage, for which damages is that party liable?
Holding and Rule: A party is liable for damages for the proximate results of that party’s acts but not for remote damages.
In Vaughan v. Menlove, the hay rick was burned, the owner’s buildings were destroyed, and thence the fire spread to the plaintiff’s cottage, which was also consumed. The defendant was held liable.
The court held that sparks and cinders falling on a building are the proximate cause of a building’s destruction. However, if the fire spreads and other buildings are consumed before reaching that of the plaintiff, accidental and varying circumstances such as the direction of the wind and the condition of the other structures etc. are the cause. Such conditions and circumstances are beyond the control of the party and that party is not liable.
In this case the damages incurred were not the immediate, but rather the remote result of the negligence of D. The immediate result was the destruction of D’s own wood and sheds; beyond that it was remote.
Public Policy: To hold otherwise would subject everyone to a liability against which no prudence could guard. Nearly all fires are caused by negligence, in its extended sense. To hold that a party must guarantee the security of his neighbors on both sides, and to an unlimited extent, would be to create a liability which would be the destruction of all civilized society. In a commercial country, everyone, to some extent, risks the hazard of his neighbor’s conduct, and each is able to obtain a reasonable security against loss through insurance.