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.
• Anderson presented evidence that the fire was set by a train owned by Minneapolis.
• However, Minneapolis presented evidence that there were other fires burning in the area at the time, and perhaps that was the cause of Anderson's damage.
• The Trial Court found for Anderson. Minneapolis appealed.
• The jury was instructed to determine if the Minneapolis train was a material or substantial element in causing Anderson's damages.
• The Appellate Court affirmed.
• Minneapolis unsuccessfully argued that if the property was damaged by a number of fires, including the one Minneapolis caused, and the damage would have occurred even if Minneapolis' train wasn't involved, then Minneapolis is not liable. (See Cook v. M., St. P. & S.S.M. Ry. Co. 98 Wis. 624, 74 N.W. 561).
• This case doesn't meet the 'but for' standard, as in, "Anderson wouldn't have been damaged but for Minneapolis's negligence."
• 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 two negligent defendants who both started fires, and both would be able to say that even if they weren't negligent Anderson still would have been damaged so therefore there's no liability. This Court felt that somebody should be liable for Anderson's damage.