Summary of Reynolds v. Texas & Pac. Ry. Co., Ct. App. Louisiana, 1885
Natural and ordinary course of events
Relevant Facts: PL Mrs. Reynold emerged from a sitting room where she was awaiting an incoming train which was late. As she left the room and headed down the steps she misstepped and fell down the stair. She came to rest on the bottom and was seriously injured.
Legal Issue(s): Whether the failure to have adequate lighting was the cause in fact of the harm?
Court’s Holding: Yes
Procedure: Trail Ct. awarded Pl $2000 without jury. Df appealed 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: Negligence of Df greatly multiplies the chances of accident to the Pl and is of a character naturally leading to it occurrence, the mere possibility that it might have happened without the negligence is not sufficient to break the chain of cause and effect between the negligence and the injury. The evidence connects the accident with the negligence.
Plaintiff’s Argument: The failure to adequately light the stairs or provide a handrail caused the injury.
Defendant’s Argument: The accident to the PL would have occurred during the daylight and was only an intervening factor.
Propter hoc – for this
Post hoc – after this