Tuesday, September 25, 2012

Vaughan v. Menlove (1837) (fire because of haystack fire hazard)


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

No comments:

Post a Comment