Biddinger v. Steininger-Taylor Co.

18 Ohio N.P. (n.s.) 42
CourtHardin County Court of Common Pleas
DecidedJuly 1, 1915
StatusPublished

This text of 18 Ohio N.P. (n.s.) 42 (Biddinger v. Steininger-Taylor Co.) is published on Counsel Stack Legal Research, covering Hardin County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Biddinger v. Steininger-Taylor Co., 18 Ohio N.P. (n.s.) 42 (Ohio Super. Ct. 1915).

Opinion

Henderson, J.

Naturally, by reason of the short period of time during which workmen’s compensation laws have been in operation, precedent-[44]*44affords little in the way of first aid to the case stated; the converse of the case has been decided by the Essex county court of common pleas of New Jersey, Perlsburg v. Muller, 35 N. J. Law Jo,. 202, and by the Industrial Commission of Ohio, Ridorfo v. Telephone Co., No. 3139; in both of these cases it was held that an injured employee, after accepting settlement for his claim for damages from a stranger wrongdoer might still successfully prosecute a claim against his employer for compensation for the same injury.

Aside from these decisions and the light they may afford the court is remitted, for a solution of the case stated, to a consideration of the language of the workmen’s compensation law, of the reasons for its enactment and of the nature of the relief or compensation awarded by it, together with a consideration of the familiar action at law for damages for personal injuries and the nature of the remedy it gave.

The action at law for damages for personal injuries existed under the common law of England; originally it is probable that its remedy was given entirely independent of any fault or breach of duty on the part of the defendant, being based on the rude principle of justice coeval with the beginnings of civil society — “An eye for an eye and a tooth for a tooth;” at a period in the development of the common law antedating its adoption in this country, however, an award of damages in this action (with some particular exceptions) came to be based and dependent on Some tort delict or breach of duty on the part of defendant, in short, upon defendant’s negligence, as we commonly understand and state it, or upon his wilful tort.

Confining our attention to that class alone of actions of trespass wherein defendant’s negligence was the determining element of his liability, and still further restricting ourselves to the subclass which concerns itself with actions by employee against employer for damages for personal injuries suffered by the former in the course of his employment, the damages given (except in eases of wrongful death wherein under statutes a different rule was laid down) were intended to be a full equivalent for the injuries suffered, as well as money could measure such injuries; [45]*45accordingly, juries were told to take into account not only physicians’, surgeons’ and nurses’ bills for care, skill and attention, loss of time and diminished earning capacity of the injured employee himself, but such uncertain and speculative elements as his physical pain, distress and anguish, probability of a shortened life, loss of limb, eye or other organ, any maiming or bodily deformity, impairment of usual faculties, physical or mental; consideration of such elements of damages was logically necessary in attempting to measure out full compensation, but it deprived a verdict in any given case of every element of certainty and substituted instead a speculation wherein sympathy, prejudice and sentiment might play the leading part.

As this common law method came to be tested by the needs of modern industrial society, its inefficiency became, year by year, more apparent. The protracted litigation to which it gave rise, with its attendant high expense, the uncertainty of the final outcome and the temptation to gamble on the amount of recovery, were vexatious and unjust to employee and emyloyer alike; it became a scandal in the legal profession, a reflection upon the court and a burden and blemish upon the civil state; hence the recent substitute for it — the compulsory employee’s compensation law.

In construing the extent and meaning of a statute amendatory of the common law, Blackstone suggests three points of consideration of cardinal importance, to'-wit: The old law, the mischief and the remedy. The old law and the mischief have just been rapidly and superficially sketched: as to the remedy, the new law gives the employee a certain right to fixed compensation, and takes away, in great measure, his uncertain right'to indefinite damages, at the same time imposing upon the employer a certain liability to pa,y a fixed annual premium and relieving him of an uncertain liability for indefinite damages; it renders protracted litigation, or litigation at all, unnecessary, and the high expense formerly incident thereto, impossible; the nature of the relief given is different; instead of attempting to estimate a full equivalent in damages for the injury, once for all, which must necessarily involve the varying and speculative elements [46]*46above alluded to, it makes no attempt to measure pain, distress of body and mind, tlie loss of an eye or limb, etc., in dollars, but awards, instead by rules fixed in advance for all cases, a stated periodical payment, based on tlie employee’s former wages and the probable disabling effects of his injuries.

In framing and passing this law, the Legislature had in mind problems growing out of the relation of employee and employer alone; it modified and in great measure took away from the former his right to sue the latter at law for personal injuries received in the course of employment; but in the general situation itself, there is nothing to warrant a belief that it was considering or intending to take from a citizen his right at common law to hold strangers accountable for failing to use ordinary care toward him; still less that it was aiming to render negligence safe and immune from liability, provided only that it be indulged in by one citizen, not toward his employee but toward a workman engaged in the employment of another.

The language and terms of the new law are next to be examined. 4. right of action previously existing is not to be deemed taken away by a new law unless done'in express terms or by an implication which seems unavoidable; it is not claimed that the express terms of the new law takes away any previously existing right of action from a workman, except those subsisting between himself and his employer and arising out of the relation of such employment.

The express language of Section 25 limits the waiver therein referred to, to rights of action against the employer; the first sentence of the second paragraph of Section 29 is not so explicit; but the context, particularly the following sentence and the preceding paragraph, makes it very plain that the option referred to in the first sentence of tlie second paragraph, is the same option described in the first paragraph, i. e.,.an option to apply for an award under the act or to sue the employer in the courts.

It is finally contended that plaintiff’s receipt of an award under the workmen’s compensation law operated as a satisfaction of the injury complained of by her in her petition; that [47]*47the injury, having thus been satisfied, no longer survives to support an action and that it is immaterial, so far as the legal effect of a satisfaction for a tortious injury is concerned, whence or from whom the satisfaction comes. Miller v. Beck, 108 Iowa, 575.

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Related

Miller v. F. Beck & Co.
108 Iowa 575 (Supreme Court of Iowa, 1899)

Cite This Page — Counsel Stack

Bluebook (online)
18 Ohio N.P. (n.s.) 42, Counsel Stack Legal Research, https://law.counselstack.com/opinion/biddinger-v-steininger-taylor-co-ohctcomplhardin-1915.