Losee v. . Buchanan
51 N.Y. 476 · New York Court of Appeals · 1873
Facts
The plaintiff's premises were damaged by the explosion of a steam boiler. The defendants, including the Saratoga Paper Company and Buchanan, had placed and operated the steam boiler on their own lands. The plaintiff claimed the defendants were liable for the damage without proof of any negligence. The defendants operated the boiler with care and skill, and the explosion was accidental. The plaintiff's claim was that the casting of the boiler upon his premises was a direct trespass.
Procedural history
At the first trial, the presiding judge dismissed the complaint against the manufacturers and held other defendants strictly liable, excluding negligence evidence. Upon appeal, the General Term reversed this, granting a new trial and holding that liability required proof of negligence. At the second trial, the jury decided against the Saratoga Paper Company and in favor of the other two defendants on the question of negligence. This court is reviewing the refusal to rule that defendants were liable without negligence, and also alleged errors in the jury charge. The order of the General Term was reversed, and the judgment entered upon the verdict was affirmed.
Issue
Is a party strictly liable for damages caused by the accidental explosion of a steam boiler on their property, even if they operated it with care and skill and were not negligent?
Holding
No. The court held that the defendants were not liable for the damages caused by the accidental boiler explosion without proof of fault or negligence on their part. The judgment in favor of the defendants was affirmed.
Rule
The court established that, in the United States, liability for injuries to person or property generally requires proof of fault or negligence. It rejected the English strict liability rule from Rylands v. Fletcher for inanimate objects like steam boilers. The court reasoned that while one must use their property so as not to injure a neighbor, this rule is modified by the exigencies of society, such as the need for factories and machinery. Accidental and unavoidable damage from lawful acts, not constituting a nuisance and managed with care, does not incur liability.
Read the full opinion on CourtListener
Case brief last reviewed . Prepared by CaseReader from the published opinion.