Ryan v. New York Central Railroad Company

New York Court of Appeals · 1866 · Torts

35 N.Y. 210 (1866)

Updated July 23, 2026

TortsNegligenceProximate CauseRemote DamagesFire Lossfire spreadnatural consequencesordinary result

Facts

In Syracuse, the defendant allegedly carelessly managed, or maintained in insufficient condition, one of its engines, which set fire to the defendant's woodshed and a large quantity of wood. The plaintiff's house stood 130 feet away and soon caught fire from the heat and sparks and was completely destroyed despite diligent efforts to save it. Other houses were also burned as the fire spread. The plaintiff sought to recover the value of his destroyed house from the railroad.

Issue

When a fire is negligently started on the defendant's property and destroys that property, is the defendant also liable to the owner of another building that is later burned after the fire spreads from the first building? More specifically, are such damages proximate or remote?

Rule

A person is liable in damages for the proximate, natural, or necessary consequences of his acts, but not for remote damages. In the case of a negligently started fire, the destruction of the property directly ignited is the immediate and ordinary result, but destruction of other buildings reached only after the fire spreads depends on accidental and varying circumstances and is therefore remote.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Buffalo, Orion Freight Lines negligently operated a locomotive so that burning cinders fell directly onto Lena Ortiz's detached garage roof. The garage immediately caught fire and was destroyed before the flames reached any other structure.

If Lena sues Orion Freight Lines for the loss of the garage, what is the most likely result?

Explanation. The majority rule distinguishes between property directly reached by the defendant's sparks and property burned only after a fire spreads. When the defendant's negligent sparks directly ignite a building, its destruction is the natural, ordinary, and immediate result of the negligence, so the loss is proximate rather than remote.