Hall & Lindley v. Rising Sun Insurance

1 Disney (Ohio) 308
CourtOhio Superior Court, Cincinnati
DecidedMarch 15, 1857
StatusPublished

This text of 1 Disney (Ohio) 308 (Hall & Lindley v. Rising Sun Insurance) is published on Counsel Stack Legal Research, covering Ohio Superior Court, Cincinnati primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hall & Lindley v. Rising Sun Insurance, 1 Disney (Ohio) 308 (Ohio Super. Ct. 1857).

Opinion

Spencer, J.

The petition states that a policy of insurance was executed by defendant, insuring the sum of $1,740 on one hundred and forty-five tons of hay, shipped on a flatboat from Yevay, Indiana, to New Orleans, valued at $12 per ton, against loss arising from the perils of the river, etc.; that the boat ran aground at or near Paducah, and resisted all efforts to get her off; that a boat had to be procured to lighten her off, by taking out the hay; that while so engaged, the flatboat broke up, and wa,s entirely destroyed; that the hay was all saved at considerable expense, in a damaged condition, except two bales, which were entirely lost; that the policy contained a clause prohibiting the insured from disposing of the hay at the place of disaster, but required the insured to cause it to be forthwith forwarded to the port of destination, which was done at an increased freight; that expenses were incurred in unloading andloading, etc.; and in ascertaining the amount of damage done, all set forth in a schedule, for which indemnity is asked.

The answer admits the policy and loss, in accordance with [310]*310an agreed statement of facts, and protest accompanying, but does not pretend that tbe boat was unseaworthy.

The facts show a loss within the perils insured against; and as there is no claim of unseaworthiness set up in the answer, we can not find it under the mere inference which may arise from the fact set. forth in the protest.

The only question we are called upon to determine is, whether such a loss has been sustained as can be compensated under the terms of the policy. It reads as follows: “ Touching the perils, etc., they are of the rivers, jettisons, enemies, and overpowering thieves; provided that the insurers shall not be liable, except in cases of general average, for any loss or damage on hoop or sheet iron, etc., hay, hops, fruit, etc., salt, hides, etc., unless it amount to twenty per cent, on the aggregate value of such articles; nor for loss or damage on flax, etc., unless it amount to ten per centón the whole value at risk, exclusive of all charges and expenses incurred for the purpose of ascertaining and proving the loss.”

When property is partially damaged by any of the perils insured against, the mode of ascertaining a loss is to com-¡ pare the damaged sales with the sound sales, at the port of destination, and whatever the difference may be, is the ratio or proportion of loss taken upon the sound sales. In the. present case it is shown, by the agreed statement of facts, that the market price of sound hay, at New Orleans, was. $21.50 per ton, equal to $3,117.50, while the gross damaged sales were $2,795.96, showing a loss of $321.54 on $3,117.50, equal to $179.47 on $1,740, the value of the hay, or a trifle over ten per cent. Unless, therefore, some other charge can be added to this, the loss does not fall within the policy,

The plaintiffs claim to charge, as part of the loss, an item of $176, being the sum paid the “Tom Scott” for towing flatboat to the rescue of the hay, and for the use of the flat, in making the rescue. This, added to the former, item, makes the loss amount to twenty per cent, on the value of the property, provided it can be properly so added under this memorandum clause in the policy.

[311]*311It seems remarkable that in determining a question which must have been of frequent occurrence under the memorandum article, in use for more than a century, no adjudicated case can be found on the subject, to furnish a proper guide as to what losses shall be taken into account in making up the requisite per centage of damage, so as to justify a claim under the policy; and, so far as elementary treatises, by standard writers, upon the law of insurance are concerned, they throw but little practical light upon the subject, and that of rather an obscure and doubtful character.

Arnold, 866, et seq., lays down four rules as applicable to such cases :

1st. That successive losses, happening at different times, may be coupled together, to make up the full amount, but they must be losses arising from the perils insured against.

2nd. That general and particular average can not be added together to make up the rate per cent, required.

3d. “That expenses incurred for saving or preserving the cargo and freight, i.“e., warehouse rent at an intermediate port, and expenses of unloading and reloading, can not be added to the damage in order to make it up to the required amount.” Eor this he cites Stevens on Av. 5th ed. 280; Benecke on Indemnity, 472. The reason given is, that these expenses are not in the nature of a loss, but are charges incurred to preserve and bring forward the property. “ The clause,” he says, “ only contemplates a loss, and that such a loss should arise from an accident. If, however, the loss, independently of these charges, exceeds the per centage, then the charges must be paid by the insurer.”

4th. “ That the expenses of ascertaining the amount of the loss can not be added to the damage to make up the required per centage.” Eor this he cites 2 Phil. 509 (485), §1791. But that it is to be recovered if the rate per cent, is complete without it. Ibid.

Phillips, in his standard work on insurance, lays down [312]*312the first, second and fourth of Arnold’s rules, §§1779, 1780, 1791, but wholly omits the third and most material one to the present inquiry. So far as he does allude to the third, rule, it is to be inferred that he holds the law to be the other way, though he does not say so in terms. He asks, section 1779, “ What damage or loss is to be included in making up the amount of loss?” and then answers: “ General and particular average can not be included together, nor the cost of ascertaining the loss.” But as to salvage, increased freights ánd other incidental charges, he is silent. If nothing but a direct loss of the thing itself were allowable, the mere statement of that proposition would have fully answered his inquiry, and left nothing to be said. In section 1790, Mr. Phillips asks the question whether the premium is to be included in the valuation of the property, in order to fix the rate per cent., and by way of answer, says: “ If the loss is a part of the thing insured, it makes no difference whether the premium is or is not included in making the adjustment, for it must enter into the value of the part lost as well as of the whole property. But if the loss is in disbursements, the omission of the premium in estimating the value of the article, may have the effect of rendering the underwriters liable for a loss for which they would not be liable were the premium included.” For which reason, he thinks, the most scientific mode of adjustment is to include the premium in estimating the value, and as being that referred to by the parties in fixing the rate per cent.

It will thus be seen that he considers the rule to be that disbursements on account of the property, to save it from peril, or further damage, are to be treated as a loss, in the making up of the requisite per centage.

Martin shows the propriety of this rule in a paragraph written for another purpose. He says, the warranty in the memorandum clause is “ free from an average, i. e., loss, the terms being used synonymously, and not from sea-damage, and an average has always been made up with the extra charges. They form a part of the indemnity which the [313]

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Bluebook (online)
1 Disney (Ohio) 308, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hall-lindley-v-rising-sun-insurance-ohsuperctcinci-1857.