Katko v. Briney
183 N.W.2d 657 · Supreme Court of Iowa · 1971
Facts
Plaintiff and a companion broke into the defendants' unoccupied, boarded-up farmhouse to steal antique bottles. The defendants, frustrated by prior trespasses, had set a 20-gauge spring shotgun rigged to fire when a bedroom door was opened. Plaintiff was severely injured by the shotgun, leading to a jury award of $20,000 actual and $10,000 punitive damages, which the trial court upheld.
Issue
May a property owner use a spring gun, capable of inflicting death or serious injury, to protect personal property in an unoccupied, boarded-up farmhouse against trespassers and thieves?
Holding
No. The court affirmed the lower court's judgment, holding that an owner may not use a spring gun capable of inflicting death or serious injury to protect personal property in an unoccupied farmhouse against trespassers and thieves.
Rule
The law places a higher value on human safety than on mere property rights, thus prohibiting the use of force calculated to cause death or serious bodily injury to repel a threat to land or chattels, unless there is also a threat to personal safety justifying self-defense. A property owner cannot use a mechanical device to inflict harm that they could not lawfully inflict in person.
Read the full opinion on CourtListener
Case brief last reviewed . Prepared by CaseReader from the published opinion.