Atlantic Coast Line R. Co. v Daniels Relevant Facts: While one driving an automobile over three railroad tracks at a crossing PL was confined thereon by the sudden lowering of the gates, he threw his brakes on in full emergency and stopped the car, but did not change the spark and gas levers. The towerman cried to him to move the car, a train was coming, Pl released the brakes and with an abnormal degree of strength, caused by the excitement, pushed the car from the first track to the second track, whereupon the towerman told him to move the car again, that the train was coming on the middle track, which he did just in time to escape the train, and thereafter in starting his car forgot, in his excitement, the condition in which he had left the levers, and attempted to start it with the maximum power turned on, resulting in the engine "kicking back," throwing him against the radiator, and breaking out several of his teeth, and inflicting other injuries. a question for the jury. Legal Issue(s): Whether the injury suffered a direct result, or proximate cause of a wrongful act by the Df ? Whether the towerman's acts were negligent, and such as to produce such a degree of fright in a normal person as to cause the injuries complained of. Court’s Holding: Yes Procedure: Judgment for plaintiff, and defendant brings error. Affirmed. Law or Rule(s): If a man has been robbed of his power of judgment by some act not within his control, his resulting lack of judgment becomes a part of the circumstances to be considered. It is in accordance with the rule we have stated to compare his conduct with the conduct of an ordinarily prudent man under similar circumstances. Court Rationale: At this point the company maintains crossing bars, controlled from a signal tower located near the crossing. When the bars are up, this is a signal to the public that they may cross without danger from the trains. The plaintiff, as he approached the crossing, saw that the bars were up, indicating that the way was clear. As the approach was considerably upgrade, he threw the levers, which control the spark and the mixture of gasoline vapor admitted into the engine, into such a position as to give the machine its maximum of 18 horse power. As he came upon the tracks, the towerman suddenly lowered the bars on both sides of the crossing, thus penning him in, upon the tracks. If the negligence had not occurred, the fright would not have ensued. So, in the broad sense, the negligence was the cause of the fright. Plaintiff’s Argument: The towerman’s actions of penning Pl w/i the crossing was negligent, and the successive negligent acts created the injury. Defendant’s Argument: the defendant's negligence cannot be considered as the proximate cause of the plaintiff's injury; that the injury was not a natural or a reasonably to be anticipated effect of the defendant's act
Ryan v N. Y. Central R. R. Co.
Relevant Facts: The N Y Cen R Co, by the negligent manner of conducting an engine, or by the defective condition of the engine, set fire to a quantity of wood in one of their sheds. The fire consumed the woodshed, and spread to and consumed the house of the plaintiff, situate about one hundred and thirty feet distant from the shed. A number of other houses were also burned by the spreading of the fire. Legal Issue(s): Whether when a house in a 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? Court’s Holding: No Procedure: The judge at the Circuit nonsuited the plaintiff, then fifth district affirmed. Affirmed. Law or Rule(s): Every person is liable for the consequences of his own acts. He is thus liable in damages for the proximate results of his own acts, but not for remote damages. Court Rationale: The result of this firing of the Pl’s building depends upon a concurrence of accidental circumstances, such as the degree of the heat, the state of the atmosphere, the condition and materials of the adjoining structures and the direction of the wind. These are accidental and varying circumstances. The party has no control over them, and is not responsible for their effects. The reason that the damages incurred are not the immediate but the remote result of the negligence of the defendants. The immediate result was the destruction of their own wood and sheds; beyond that, it was remote. The negligent burning of a house, and the spreading of the fire to a neighboring house, and the burning thereof, do not give the owner of the last house a cause of action against the owner of the house in which the fire originated. The damages are too remote. Plaintiff’s Argument: Df’s negligent actions directly caused the destruction of pl’s building. Defendant’s Argument: The reason that the damages incurred are not the immediate cause of the df’s negligence but the remote result of the negligence of the defendants.
Bartolone v Jeckovich
Damages--Inadequate and Excessive Damages--Aggravation of Preexisting Illness
Relevant Facts: Pl was involved in a four-car chain reaction collision in Niagara Falls for which defendants were found liable. Pl sustained relatively minor injuries consisting of whiplash and cervical and lower back strain for which he was treated with muscle relaxants and physical therapy but was not hospitalized. Since the accident, pl has been in a degenerative psychotic condition in which he is withdrawn, hostile, delusional, hears voices and sees shadows, refuses to cut his hair, shave or bathe and no longer participates in any of his former interests. Io the words of his treating psychiatrist, he is "a life lost". Subsequently, however, he suffered an acute psychotic breakdown from which he has not recovered. Legal Issue(s): Whether the jury could conclude that plaintiff's total mental breakdown could be attributed to a minor accident? Court’s Holding: Yes Procedure: The jury returned a verdict of $500,000 in pl's favor. The court granted dfs' motion to set aside the verdict and ordered a new trial unless pl would stipulate to a reduced verdict of $30,000. Pl refused and took this appeal. The order should be reversed and the verdict reinstated. Law or Rule(s): A defendant must take a plaintiff as he finds him and hence may be held liable in damages for aggravation of a preexisting illness. Court Rationale: plaintiff, although apparently suffering from a quiescent psychotic illness, had been able to function in a relatively normal manner until the accident, which aggravated his schizophrenic condition leaving him totally and permanently disabled; a defendant must take a plaintiff as he finds him and, therefore, may be held liable in damages for aggravation of a preexisting illness; moreover, plaintiff should not be denied recovery because his condition might have occurred even without the accident. Plaintiff’s Argument: The theory on which pls case was tried was that the accident aggravated a preexisting paranoid schizophrenic condition which has totally and permanently disabled him. Defendant’s Argument: The pl’s pre-existing condition was the cause of the injury.