Hastings v. Halleck

2 Cal. Dist. Ct. 218
CourtSan Fransisco District Court
DecidedMarch 15, 1858
StatusPublished

This text of 2 Cal. Dist. Ct. 218 (Hastings v. Halleck) is published on Counsel Stack Legal Research, covering San Fransisco District Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hastings v. Halleck, 2 Cal. Dist. Ct. 218 (sfdistct 1858).

Opinion

NORTON, J.,

charged the jury. This case, the trial of which has occupied your attention for the last few days, is of a peculiar character, and one which is not very frequently presented. The principal difficulty involved in the case is, that the jury are required to pass upon the conduct of professional men, in regard to the degree of skill and diligence which they have exhibited in the course of the performance of their professional duties — a difficulty encountered in the decision of all cases of this nature, but which becomes materially enhanced when the conduct or acts of attorneys becomes the subject of consideration. In these cases, perhaps, ordinarily the court can best judge as to the real merits of the controversy. Generally, in cases involving the question of the liability of persons following a distinct trade or occupation, such as that of a mechanic, for example, for damages resulting from their alleged unskillfulness or carelessness, neither court nor jury decide upon that question from their own individual judgment or their knowledge of that trade. In such cases witnesses are introduced and examined touching the precise point involved, and the question is then determined according to their testimony. In these cases there is generally but little difficulty. In the case before you, however, no [242]*242such testimony has been adduced, for the reason, probably, that the expectation has been that the court -would so instruct you as to enable you to arrive at a correct conclusion from a consideration of the facts bearing upon this question, which have been proven upon the trial. In some of the cases to which I have been referred, the court has instructed the jury directly and positively upon this matter of negligence as a question of law, while in others the jury have passed upon it, under general instructions from the court, according to their own judgments.

That which, in my opinion, constitutes the most important, and which must be the controlling, fact in this case, was only brought to my attention towards the conclusion of the argument of counsel yesterday, and upon reflection I can see but very little for the jury to pass upon. In my opinion the liability of the defendants must be determined by the decision of questions which are in themselves essentially questions of law, and therefore addressed to the court, and not to the jury, for decision.

A determination of the question as to the liability of these defendants, renders it necessary, to some extent, to reconsider the action of Adams v. Hastings. That was instituted, as the evidence has shown you,- for the recovery of a certain indebtedness of Hastings to those plaintiffs, which was created on his behalf in his absence by his agents and attorneys in fact. Haven and Brieeland, and the principal question there raised and discussed was, whether or not they, the attorneys, had the authority to contract that indebtedness.

Their power, whatever its extent, was derived through and by virtue of the power of attorney executed by Dr. Hastings upon his departure for the eastern states. Being then solely conferred by this instrument, its extent and limitations must be determined by the construction which shall be put upon the power of attorney; and this, like all other questions of a similar character, that is, all those arising in the determination of the scope and effect of written instruments, is a matter of law, to be passed upon by the court. It is true that questions of this character are often submitted to juries for them to pass upon, but always accompanied by direct instructions from the court, charging them that if they shall find that the evidence discloses the existence of a certain [243]*243state of facts, then from these facts the law implies a certain consequence, which is also declared to them, and which they are instructed to express by their verdict; so that, as matter of practical effect, sub mitting the construction of a legal instrument to a jury, is rather a matter of form than an actual submission of the question to them— their real province being to determine the exact facts and circumstances the existence of which the testimony has disclosed.

Such a case would be presented here if the former action of Adams v. Hastings were at present before you ; but the principal difficulty encountered now, arises mediately from the fact that you are not exactly trying the issue between Adams Co. and Dr. Hastings. The question is as to the manner in which Halleck, Peachy Billings defended that action — it is their conduct which you are to consider— their professional conduct in a matter entrusted to their charge in their character as attorneys. And with regard to this matter I shall charge you as requested, that the presumption is that defendants did discharge their duty to Dr. Hastings as professional men — that the burden of proof lies with him, and in order to recover, it is incumbent upon him to establish affirmatively the fact of negligence and want of due diligence on the part of defendants. Hastings may not have any right to a recovery against them, merely because they did not successfully defend the action in the superior court, and that may hold true, although they might, perhaps, have brought it to a different determination. The main proposition is, that they are liable for damages arising from a want of a reasonable degree of diligence and skill. It is not required of an attorney that he should exhibit the utmost professional skill in the conduct of a cause ; in order to charge him with a liability for a loss resulting to his client, it is not sufficient that the jury should simply believe that the action might have been more successfully prosecuted (though, this fact must be established before a liability can be attached) — but he will be liable for whatever damage the client may have sustained by reason of his failure to exercise ordinary and reasonable skill and care.

This proposition is true of all the professions and trades. In the merely mechanical trades — in those in which manual dexterity is the [244]*244predominant feature — the question of ordinary and reasonable skill, presents, as I said, but little difficulty ; but where the occupation is one requiring the exercise of the mental, rather than the physical powers ; where the operation to he performed must he done according to the dictates of the judgment, as it shall deem advisable; where the difficulty, whatever there may be in the operation to be undertaken, ■is to be overcome by mental, and not merely manual or physical exertion ; then in all such cases the difficulty of determining the question, whether or not the operator exhibited ordinary and reasonable care or skill, is much greater. To take an example of each of the different classes, as, for instance a wheelwright and a surgeon. In the case of the former, no matter what the particular piece of work, which he was called upon to perform in the course of his business, might have been, it would be difficult to conceive of one in which it would not be easy to declare whether or not he had exhibited a want of ordinary professional skill. But in the second case — that of the surgeon — there might be more difficulty than could arise in the case of the wheelwright.

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Bluebook (online)
2 Cal. Dist. Ct. 218, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hastings-v-halleck-sfdistct-1858.