A house in a populous city takes fire, through the negligence of the owner or his servant; the flames extend to and destroy an adjacent building: Is the owner of the first building liable to the second owner for the damage sustained by such burning?
Torts I, Pages 315–316
Ryan v. New York Central R.R. Co.
Court of Appeals of New York, 1866
Facts:
Defendants negligently lit its woodshed on fire. This fire spread to plaintiff's house and a number of others.
Procedural History:
Circuit judge nonsuited the plaintiff, and the General Term of the fifth district affirmed.
Issue:
Rule:
The damages incurred must be the immediate result of the negligence of the defendants.
Reasoning:
People should not be liable for unusual results of their actions, as it could lead to people being liable for damages greater than they could possibly afford. People can best insure themselves against potential damages. Defendants lit their own building on fire, and shouldn't be held liable for it spreading to plaintiff's. There are too many condition the defendant has no control over.
Holding:
The defendants are not liable for their building on fire spreading to plaintiff's. Affirmed.