a. Facts-
Δ and Π lived close to each other. Δ built a haystack on his property, which
his neighbor told him is a fire hazard. Δ decided to leave the haystack in its
place, and not move it. Later, Δ built a chimney around the haystack. The
haystack then caught on fire, and destroyed some of Δ’s property as well as Π’s
property. Π sued Δ for negligence. After Trial Ct found for Π, Δ argued that he
“ought not to be responsible for the misfortune of not possessing the highest
order of intelligence”.
b. Procedural
History- Trial Ct found for Π, Δ appealed, Ct of appeals affirmed.
c. Issue-
Whether the jury must evaluate Δ’s actions based on an objective standard, or take
into account Δ’s sub-prime intelligence
i.
Whether the standard of intelligence for
negligence is that of the “highest order”
d. Holding-
Yes, the jury MUST evaluate negligent actions from the viewpoint of an
objective standard, not the actual intelligence capacity of the Δ
e. Rule-
The standard of negligence is objective. One is negligent if they acted
differently than how a prudently reasonable person would have acted
f. Rationale-
i.
If we apply a different standard for
different Δs, then there would effectively be no Rule at all
g. Notes-
i.
The hay burned b/c of spontaneous
combustion…how is it possible that everyone knows about this?
ii.
A Δ cannot claim to be “unintelligent”
and therefore not be responsible for damages arising from said “unintelligent”
iii.
Particular sensitivities and weaknesses
should not be taken into account when determining if a Δ acted as a reasonable
person should have, for negligence actions
iv.
People cannot fraudulently claim
sub-prime intelligence in an effort to evade answering actions
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