Anderson v. Minneapolis, St. Paul & Sault Ste. Marie Railway
146 Minn. 430, 179 N.W. 45 (1920)
Anderson's property was burned
in a fire. He sued Minneapolis for negligence.
Anderson argued that the
fire was set by a train owned by Minneapolis, so they were responsible
for the damage.
However, Minneapolis argued
that there were other fires burning in the area at the time, and perhaps one of
those was the cause of Anderson's damage.
If Anderson's property was
damaged by a number of fires, then the damage would have occurred even
if Minneapolis' train wasn't involved, so Minneapolis is not liable.
(See Cook v. M., St. P. & S.S.M. Ry. Co. (98 Wis. 624, 74 N.W. 561)).
argued that this case doesn't meet the but for standard, as in, "Anderson wouldn't have
been damaged but for Minneapolis's negligence."
The Trial Court found for
Anderson. Minneapolis appealed.
The jury was instructed that
if the Minneapolis train was "a material or substantial element in
causing Anderson's damages," then Minneapolis was liable.
The Appellate Court affirmed.
The Appellate Court decided
that in a case like that, all of the people who caused a fire would be jointly
and severally liable.
In this case, the traditional but
for test doesn't seem very just. You
have multiple negligent defendants who all started fires, and they all
claim that even if they weren't negligent Anderson still would have been damaged so
therefore there's no liability.
The Court felt that somebody should be liable for Anderson's damage.