Rylands v. Fletcher Exchequer: 3 Hurl & C. 774 (1865), Exchequer Chamber: L.R. 1 Exch. 265 (1866), House of Lords: L.R. 3 H.L. 330 (1868) Rylands owned a mine. Fletcher owned a nearby mill. Fletcher was trying to build a pond to supply water to the mill, but the ground gave way, the water flooded Fletcher's property, and the runoff flooded Ryland's mine. Rylands sued for trespass and damage to the mine. The Trial Court (Court of the Exchequer), found for Fletcher. Ryland appealed. o The Court of the Exchequer felt that to constitute trespass, the act doing the damage must be immediate. o The Court of the Exchequer also found that Fletcher had been doing a legal act on his own land, and they could not be held liable unless they had reason to believe that their act would become a nuisance or cause damage to people outside their land. The Appellate Court (Court of the Exchequer Chamber) reversed. Fletcher appealed. o The Exchequer Chamber felt that it made no difference whether Fletcher acted willfully or not, he still caused a nuisance and damaged Rylands' property. o If you bring a potential nuisance onto your land, and it escapes, you are answerable to all damage that is the natural consequence of that nuisance. o The Exchequer Chamber felt that this case was similar to other cases where someone's livestock had broken free and eaten a neighbor's crops. In cases like that, strict liability applies. It is foreseeable that cattle will stray, is it foreseeable that the water might escape and flood a nearby mine? The English Supreme Court (the House of Lords) affirmed. o The House of Lords found that if the water was natural runoff, then Ryland's had nothing to complain about, but if the water was from Fletcher's intentional actions, especially if he was doing something that the natural Project Wonderful - Your ad here, right now, for as low as $0 land wasn't capable of supporting, then Fletcher was acting at his own peril. This case helped establish that there is strict liability for some tort claims. It was the opposite of the US case of Brown v. Kendall (60 Mass. (6 Cush.) 292 (1850)), which moved US case law away from the strict liability standard to a fault-based liability. This case does not do any kind of cost balancing and does not consider economic impacts. Could you have argued that there was some negligence on the grounds of res ipsa loquitur? o The difference between res ipsa loquitur and strict liability is that under res ipsa loquitur, the thing would not have occurred without some negligence, but you don't have enough details about what happened to determine exactly what the negligence is. In strict liability, you have a very good idea of what happened, but there doesn't seem to have been a negligent act.
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