Anderson v. Minneapolis, St. Paul & Sault Ste. Marie Railway Co.

Supreme Court of Minnesota · 1920 · Torts

tortscausationsubstantial factorconcurrent causesfiresubstantial factormaterial elementconcurrent causes

Facts

Plaintiff's property burned shortly before it was reached by one of the great fires sweeping northeastern Minnesota on October 12, 1918. Plaintiff claimed the damage was caused by a bog fire set by defendant's locomotive, while defendant introduced evidence of other fires coming from the west and northwest; plaintiff then offered rebuttal evidence that those western fires near Kettle River were also started by defendant's locomotives. The trial court instructed that defendant would be liable if a fire set by its engines was a material or substantial factor in causing the damage, even if it combined with another fire not set by defendant. After the jury returned a verdict for plaintiff, the court allowed plaintiff to amend the complaint to allege that both the bog fire and the Kettle River fires destroyed the property.

Issue

Whether defendant could be held liable where a fire set by its locomotive combined with other fires and the evidence permitted a finding that defendant's fire was a material or substantial factor in destroying plaintiff's property. The case also presented whether unusual wind and drought, or other fires of unknown origin, relieved defendant of liability, and whether the complaint could be amended to conform to proof concerning the Kettle River fires.

Rule

If a fire set by a defendant's locomotive is a material or substantial factor in causing the plaintiff's damage, the defendant is liable even though that fire combines with another fire not set by the defendant, even though the other cause is an act of God, and even though the other fire may itself have been sufficient to destroy the property. An intervening cause relieves liability only if it is independent, not reasonably anticipable, and the injury would not have occurred without it; that rule does not apply where the defendant's fire remains a material concurring cause.

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In western North Dakota, a freight engine operated by Prairie Line Railways ignited dry grass along its right of way near Bismarck. Several hours later, a separate brush fire of unknown origin approached from the west, and the two fires merged before reaching Lena Ortiz's storage shed outside Mandan. The evidence would permit a jury to find that the railroad fire materially contributed to the destruction, even though the western fire might also have been large enough to burn the shed by itself.

Under the governing rule, is Prairie Line Railways liable for the destruction of the shed?

Explanation. Liability turns on whether the defendant's fire was a material or substantial element in producing the loss. When the defendant's fire combines with another fire not set by the defendant, the defendant remains liable if its fire was still a substantial concurring cause, even if the other fire may itself have been sufficient to destroy the property.