First & Merchants National Bank v. Featherston Service Stations, Inc.

9 Va. Cir. 301, 1967 Va. Cir. LEXIS 9
CourtRichmond City Circuit Court
DecidedMarch 28, 1967
StatusPublished

This text of 9 Va. Cir. 301 (First & Merchants National Bank v. Featherston Service Stations, Inc.) is published on Counsel Stack Legal Research, covering Richmond City Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
First & Merchants National Bank v. Featherston Service Stations, Inc., 9 Va. Cir. 301, 1967 Va. Cir. LEXIS 9 (Va. Super. Ct. 1967).

Opinion

By JUDGE ROBERT LEWIS YOUNG

This is a most unusual case. I have found no case like it in the Virginia reports. It is an action in tort by a fire insurance company against a tenant for years, its sub-tenant, and the latter’s servant, seeking reimbursement of monies paid to the landlord to settle a fire loss claim. Our first inquiry is, I suppose, whether the landlord had any claim against these defendants to which the plaintiff may be subrogated. 46 C.J.S., Insurance, Sec. 1211, pp. 176-180; 29A Am. Jur., Insurance, Sec. 1720, pp. 799, 801.

In Winfree v. Jones, 104 Va. 39 (1905), it was apparently assumed that a tenant could be held liable for damages caused by a fire due to his negligence, actually the act of a stranger, but the point was not discussed. In Brough v. Higgins, et al., 43 Va. (2 Gratt.) 408, 412 (1846), a controversy not directly in point here, it was said as follows:

By the strict common law rule, supposing there had been no insurance, the tenant is bound to repair, and as the statute of Anne [302]*302has not been incorporated in our code, the tenant may be bound to repair the partial injuries from fire, at least so far as to prevent future dilapidations, to which such injury may expose the building. Under this aspect of the case, which devolves on the tenant the duty to make such repairs, the injuries to be repaired are exclusively his risks; and it seems to be a plain consequence of reason and justice, that the indemnity stipulated for such injuries, should enure to him who is bound to repair them. He who suffers the loss should have the indemnity, the claim to which arises solely from the loss.

In Taylor's Landlord and Tenant, 9 th ed., vol. 1, sec. 196, pp. 255, 256, a most authoritative work, but which might be in error on this point, it is said as follows:

A tenant is answerable to his lessor, if a building on the demised premises is destroyed by fire through his carelessness or negligence; and is bound to rebuild, at his own expense, within a reasonable time.

In 4 Virginia Law Review 546 there is a most scholarly article entitled "Destruction of Buildings by Fire as Waste." While the author concludes that probably fire damages caused by a tenant’s negligence would be regarded as actionable waste (at p. 557), he states as follows (at p. 555); "In Virginia, the law touching this matter is not settled."

It would seem logical, under these circumstances, to examine the law in England before our separation from the mother country. By far, to me, the best statement is to be found in Hargrave’s Notes on Lord Coke’s First Institute or Commentary upon Littleton, published in London in 1744, note 377 to 57a, from which I quote:

(1) Action on the case doth not lie for permissive waste. 5. Rep. 13.b. Hal. MSS. — The case cited by lord Hale is that of the [303]*303countess of Salop, who brought action on the case against her tenant at will for negligently keeping his fire, that the house was burnt; and the whole court held, that neither action on the case nor any other action lay; because at common law and before the statute of Gloucester action did not lie for waste against tenant for life or years, or any other tenant coming in by agreement of parties, and tenant at will is not within the statute. But the doctrine that no action lies should be understood with some limitation; for if tenant at will stipulates with his lessor to be responsible for fire by negligence or for other permissive waste, without doubt an action will lie on such express agreement. The same observation holds with respect to tenants for life or years before the statute of Gloucester; for though the law did not make them liable to any action for waste, yet it did not restrain them from making themselves liable by agreement. It may be of use here to add something on the progress of the law as to the accidental burning of houses, so far as regards landlord and tenant. At the common law lessees were not answerable to landlords for accidental or negligent burning; for as to fires by accident, it is expressed in Fleta, that fortuna ignis vel hujusmodi eventus inopinati omnes tenentes excusante and lady Shrewsbury’s case is a direct authority to prove, that tenants are equally excusable for fires by negligence. See Fleta, lib. 1, cap. 12. Then came the statute of Gloucester, which, by making tenants for life and years liable to waste without any exception, consequently rendered them answerable for destruction by fire. Thus stood the law in lord Coke’s time; but now by the 6. Ann. ch. 31. the ancient law is restored, and the distinction introduced by the statute of Gloucester between tenants at will and other lessees is taken away; for the statute of Ann exempts all persons from actions for accidental fire in any house, except [304]*304in the case of special agreements between landlord and tenant.

It has been noted that the text in Blackstone’s Commentaries, vol. II, p. 281, may not be strictly accurate. Dorr v. Harkness, 49 N.J. Law 571. Be that as it may, probably no law book was better known here in the early days of this Commonwealth. Blackstone, at the portion of the text cited stated, in part, as follows:

Waste is either voluntary, which is a crime of commission, as by pulling down a house; or it is permissive, which is a matter of omission only, as by suffering it to fall for want of necessary reparations. ... If a house be destroyed by tempest, lightning, or the like, which is the act of providence, it is no waste; but, otherwise, if the house be burnt by the carelessness or the negligence of the lessee; though now by the statute of 6 Ann. c. 31 no action will lie against a tenant for an accident of this kind.

Sir William Holdsworth, in his most authoritative A History of the English Law, vol. VII, pp. 276, 277, discusses this subject, saying, in part, as follows:

Permissive waste.~We have seen that the medieval statutes, which regulated waste, left it somewhat uncertain whether or not a lessee for life or years was liable for permissive waste. Most of the cases seem to postulate some positive act of voluntary waste; and to require the commission of a positive wrongful act was in harmony with the medieval principles of liability for wrongdoing.

About the time of the American Revolution the learning in England was that a tenant for years was not liable for permissive waste. See note 9 to Holdsworth, pi. cit.

It is said that our statute patterned after the statute of Gloucester is that entitled "An Act Concerning Waste," passed December 26, 1792. The Revised Code of [305]*305Virginia, vol. 1, p. 462. See Dejarnette v. Allen & Wife, 46 Va. (5 Gratt.) 499 (1849). By this statute tenants by the curtesy, in dower, "or otherwise for a term of years," tenants in common, and guardians were made liable for waste, not specifying whether permissive or voluntary. Nor do I find any case saying whether this statute was intended to apply only to persons coming into possession by operation of law, as distinguished from act of the parties. It would appear to be aimed at those situations where the person in reversion had no means of insisting on a proper covenant.

Certainly our law makers and courts of that time were familiar with the two leading cases on this subject of alleged negligent fires.

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Related

Burton v. Chesapeake Box & Lumber Corp.
57 S.E.2d 904 (Supreme Court of Virginia, 1950)
Moses v. Old Dominion Iron & Nail Works Co.
75 Va. 95 (Supreme Court of Virginia, 1880)
Winfree v. Jones
51 S.E. 153 (Supreme Court of Virginia, 1905)
Kavanaugh v. Donovan
41 S.E.2d 489 (Supreme Court of Virginia, 1947)

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9 Va. Cir. 301, 1967 Va. Cir. LEXIS 9, Counsel Stack Legal Research, https://law.counselstack.com/opinion/first-merchants-national-bank-v-featherston-service-stations-inc-vaccrichcity-1967.