First National Bank v. Gillen

7 Ohio C.C. (n.s.) 33
CourtTrumbull Circuit Court
DecidedFebruary 15, 1905
StatusPublished

This text of 7 Ohio C.C. (n.s.) 33 (First National Bank v. Gillen) is published on Counsel Stack Legal Research, covering Trumbull Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
First National Bank v. Gillen, 7 Ohio C.C. (n.s.) 33 (Ohio Super. Ct. 1905).

Opinion

Plaintiff in error is tbe owner of a bank building situated on South Park avenue running along tbe public square and one of tbe most public streets in the city of Warren. The bank had a coal vault five feet deep under the sidewalk, but it had not used it for at least ten years. The entrance to this vault from the [34]*34outside was by means of an opening in the middle of the sidewalk. The opening was covered by a circular iron covering known as a grate covering twenty inches in diameter and one inch thick. This grate covering rested on an iron rim and had an iron rod with a hook attached, running down through the center for the purpose of fastening it below in the vault, but had never been so fastened. It fitted loosely in the rim and could be easily displaced so it would tilt, either by the catching of an umbrella in it or the catching of a pedestrian’s cane in it. There were a large number of openings to coal vaults in the city covered in the same manner at the time of the accident and had been for years previously as well as in cities of the same size in different parts of the country; while many grate coverings were fastened below, and some openings were covered with large solid covers that fit closely into the rims. The proper authorities of the city had full knowledge of the existence of the vault and the cover, but no permit or license was obtained to construct and maintain it by the owner of the property.

About eight o’clock in the evening of April 28, 1900, after dark, defendant in error, Barney J. Gillen, was lawfully walking along Park avenue; he stepped upon the covering; it tilted and he fell into the opening to the vault and was very seriously injured. About ten minutes before the accident the cashier of the bank in coming from the building passed over the covering and stepped upon it, without any signs of it being displaced, and after the accident the rim and covering were in good condition, showing almost conclusively that the covering had been slightly displaced by some means immediately previous to the accident, but by what means the evidence wholly fails to show.

The only error relied upon in argument for the reversal of the judgment is that the verdict is clearly against the weight of the evidence and the only question therefore is, was the jury justified in drawing the inference of negligence on the part of the bank from the facts-stated, as there is no claim of negligence on the part of Gillen.

The question is a very important one, as in almost all cities of the size of Warren there are scores of coal vaults similarly covered.

[35]*35Conceding that in this state an abutting owner of a lot has authority to excavate under a sidewalk and construct .and maintain a coal vault for his own benefit alone, about which there may be some question, yet what is his duty to the public when he does so? The sidewalk is primarily for the benefit of the public. It is especially for the use of the resident of the city when walking, and he has a right to assume that no stumbling block dr trap has been placed in the center of the walk. By day and by night he is justified in assuming that the center of the sidewalk is clear of all obstructions or pit-falls. If the owner of abutting property makes use of it for his own convenience by excavating under it, he must see to it that the sidewalk is in as substantially safe condition as if no excavation had been made. Such, no doubt, is the law upon principle, and as we understand it such is the tenor of .the best authorities!.

In Dillon on Municipal Corporations, Sections 1032 and 1033, it is said:

“Section 1032. No person, not even the adjoining owner, whether the fee of the street be in himself or in the public, has the right to do any act which, renders the use of the street hazardous or less secure than it was left by the municipal authorities. Whoever does so, whether by excavations made in the sidewalk by the abutter, or by unsafe hatchways left therein, or by opening, or leaving open, an area-way in the pavement, or -by undermining the street or sidewalk, or by placing unauthorized obstructions thereon, which make the use of the street unsafe or less secure, is guilty of a nuisance, and is liable to any person who, using due care, sustains any special injury therefrom; and in any such eases, the person who created or continues the nuisance is thus liable, irrespective of the question of negligence on his part.
“Section 1033. In accordance with the principles stated in the preceding sections, the owner of a building and lot is liable for personal injuries sustained by the breaking of a flagstone, or defective grating formed part of the sidewalk adjoining the building and covering an excavation made in the sidewalk, and used by the owner for private purposes. It follows that it is no answer to such an action, that the work, including the defective covering, was done for the owner at a fixed price by contractors, who agreed to do it properly. The doctrine of respondeat [36]*36superior has no application to such a ease. And because the owner is bound, at his peril, to keep the excavation covered so as to be as safe as if it -had not been made, he is not discharged from liability by the fact that, having provided a sufficient covering, it was, without his knowledge, fractured or rendered unsafe by the wrongful acts of others. ’ ’
The doctrine of the text is supported by many authorities and the author well says, in commenting upon the case of Fisher v. Thirhell, 21 Mich., 1, which dissents from these authorities:
‘ ‘ Since such excavations are made for the exclusive benefit of the owner of the building the author sees nothing unreasonable in the doctrine that he is bound to see that they are kept in repair, and do not become nuisances by becoming dangerous. See also Section 700.”

It is however not necessary in this case to go the extent of holding that the bank should be held responsible for maintaining a nuisance and therefore guilty of a wrong, it having no right whatever, implied or otherwise, to make or maintain the vault, and the trial court instructed the jury that the defendant would only be liable for the want of ordinary care in constructing and maintaining the covering over the hole, and that if ordinary care was used in the construction and maintenance of the covering, they should find for the defendant. The jury found that the bank did not exercise such care as it should have done, and certainly that was a question of fact to be determined by the jury, if an inference of negligence could be drawn from the facts. Dickson v. Hollister, 123 Pa., 421.

Ordinary care in a case of this character would be great care. This coal hole was in the center of the pavement. The owner is bound to know that persons will pass and repass and step upon the cover,- not only in the day time but the night time, without apprehending danger.

“If an excavation under a sidewalk is by license of competent authority, the one making it is bound to do it in a careful manner, and to see that it is properly and carefully covered, so as to make the street as safe for passage as before.” Irvine v. Wood et al, 51 N. Y., 224.
[37]*37“The public are entitled to an unobstructed passage upon the streets, including the sidewalks of a city. A coal hole covered with a movable disc is an obstruction.

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Related

Irvine v. . Wood
51 N.Y. 224 (New York Court of Appeals, 1872)
Dickson v. Hollister
16 A. 484 (Supreme Court of Pennsylvania, 1889)
Fisher v. Thirkell
21 Mich. 1 (Michigan Supreme Court, 1870)

Cite This Page — Counsel Stack

Bluebook (online)
7 Ohio C.C. (n.s.) 33, Counsel Stack Legal Research, https://law.counselstack.com/opinion/first-national-bank-v-gillen-ohcircttrumbull-1905.