Ryan v. New York Central R.R. Co.
COA NY - 1866
- D negligently set fire to its woodshed. P's house was situated 130 feet from the shed and took fire as well. P sued D for property damage.
- Trial court dismissed P's claim.
- Appellate court affirmed.
- NY COA affirmed.
- How far should liability be extended when a D causes some damage which spreads further than the D could have reasonably foreseen?
- Liability for a D's negligence extends only to the immediate and foreseeable (proximate!) consequences of his actions.
- Ds can only insure their own goods; they can't take out insurance on their neighbor's goods. Thus, they shouldn't be liable for their destruction.
- In this case, the damage was too remote and unforeseeable to be attributed to the D.