Anderson v Minneapolis
S. Ct. Minnesota, 1920
Author:- Sam Biers

Relevant Facts: Def R.R. Company set fire to a bog which swept over a large area and connected with another fire already in existence. The combined fires burned over the Pl’s property.

Legal Issue(s): Whether the jury should have been instructed that if the original fire combined with another fire, superior in strength, but of unknown origin the Df was not liable?

Court’s Holding: Yes

Procedure: Verdict for Pl.  Df appealed order denying NOV or M. for new trial.  Affirmed.

Law or Rule(s): 1) Duty, 2) Breach of Duty 3) causation, and 4) damages.  The causation element requires proof of both cause in fact and proximate cause.

Court Rationale: If a fire is negligently started and it is the material element causing the injury whosoever started that fire is liable. When a fire joins with another and then causes the damage to the property, if either would have destroyed the property, .  The fire set by the engine was negligence, the Pl’s property was destroyed as a result. If another fire was started by another company’s engine there would be joint liability, no evidence was presented.  The material element was the negligent ignition by the engine, not the conjunction of two independent fires.  The jury was adequately instructed on either side of the causation, whether to find for the Pl or Df and the jury chose the Pl based on the evidence presented.

Plaintiff’s Argument: The material element causing the injury was the fire which was started negligently by the DF. 

Defendant’s Argument:  When a fire joins with another and then causes the damage to the property, if either would have destroyed the property, the Df is not liable.