1. William v. Hays (1894) (ship captain mentally unfit after taking medicine and destroys ship)

a.       Facts- Δ was a ship captain who was sailing Π’s ship. A storm hit and the Δ tirelessly steered the ship; the storm lasted for over 48 hours. Δ feared he had a fever or malaria so Δ took medicine, which made him mentally unfit. During the storm, multiple tugboats asked the ship if they needed help, Δ refused all help and eventually wrecked the ship. Δ does not remember anything that happened since he took the medicine to being rescued after the wreck. Π sued Δ for negligence b/c of Δ’s “carelessness and misconduct”. Δ argued that, by being mentally unfit, Δ was not responsible for the damages.

b.      Procedural History- Trial Ct found for Δ, Π appealed, Ct of appeals reversed and remanded. Trial Ct found for Π, Δ appealed, Ct of appeals reversed and remanded.

c.       Issue-

                                                              i.      Whether “lunacy” is a defense for negligence

                                                            ii.      Whether “lunacy” that is solely the consequence of taking appropriate care is a defense for negligence

d.      Holding-

                                                              i.      No, “lunacy” is NOT a defense for negligence

                                                            ii.      Yes, “lunacy” that solely stems from efforts to exercise proper care is a defense for negligence

                                                          iii.      Δ’s insanity is state of mind standard if it was caused by Δ’s efforts to save the ship

e.       Rule-

                                                              i.      An insane person is just as responsible for their actions as a sane person

                                                            ii.      If a person becomes insane solely because of exercising proper care, then insanity is a proper defense

f.       Rationale-

                                                              i.      If harm is done, either the harmer or the harmed must pay the damages. It’s better to place the burden paying damages on the harmer

                                                            ii.      The relatives of the lunatic will be encouraged to restrain him, and people will not be able to fraudulently claim insanity as a defense

                                                          iii.      Question of policy: If the public is responsible for the lunatics actions, then the public should pay damages resulting from their actions

                                                          iv.      Insanity solely from exercising proper care- If you are practicing proper care and, as a result, become insane, there is nothing you can do about it; you have done everything that is possible to exercise care. The law does NOT ask people to do impossible things

g.      Notes-

                                                              i.      Question of L turns on whether you look at it from his mental state, or the reasonable person standard

                                                            ii.      If there’s L on the insane person, the guardian of that insane person will try to “arrange life to minimize harm to others)

                                                          iii.      What if a person is faking insanity?

1.      When there is an incentive to “act” insane, people WILL act insane

2.      This is why insanity is not a defense for civil litigation