Kenning v. Interurban Railway & Terminal Co.

18 Ohio N.P. (n.s.) 526
CourtOhio Superior Court, Cincinnati
DecidedNovember 30, 1915
StatusPublished

This text of 18 Ohio N.P. (n.s.) 526 (Kenning v. Interurban Railway & Terminal Co.) 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
Kenning v. Interurban Railway & Terminal Co., 18 Ohio N.P. (n.s.) 526 (Ohio Super. Ct. 1915).

Opinion

Oppenheimer, J.

Plaintiff’s intestate, an employee of the Fairmount Brewing Company, was driving one of its wagons upon a street over which defendant’s cars were being operated. The wagon was struck by a car and he was killed. The petition alleges that the collision was caused solely by the negligence of defendant’s servants.

The third defense of the answer, to which a demurrer has been filed, alleges that subsequent to the death of plaintiff’s intestate, the widow filed an application with the industrial commission, and that an awa|6sd of $3,744, together with certain sums for funeral and other expenses, was made to her for the benefit [527]*527of decedent’s family. It is further alleged in the same defense that at the time of such payment defendant was also a contributor to the state insurance fund, and that it therefore had a direct pecuniary interest in the fund out of which the aforementioned sums were paid.

The several workmen’s compensation acts are of very recent passage, and there has therefore been given but little opportunity for interpretation by courts of last resort. In this state a careful search has revealed but two decisions which directly involve the question now before us, and they are decisions of nisi prius courts and are unfortunately irreconcilable. But we think that the solution of the question now presented is not attended with any particular difficulty.

All so-called workmen’s compensation, for which provision is made in such statutes as ours, is merely a species of social insurance. The term “compensation” is in reality a misnomer. It is not even designed to compensate the injured workman for his mental or physical suffering, for the impairment of his future earning capacity, or for many of the other things which might properly be considered by a jury in the award of compensatory damages against a tort-feasor. Indeed, the Ohio act expressly disavows any claim that the sums paid by virtue of its provisions shall be full compensation. It does not provide compensation for the first week of disability (Seetion 1465-78, General Code) ; it does not cover any medical expenses in excess of $200 (Section 1465-89) ; it provides payment after the first week for a limited period of time to the extent of only two-thirds of the injured workman’s earning capacity (Seetion 1465-80). Its manifest purpose is to secure to the employee a prompt, certain and non-litigious pecuniary relief from the hardships attendant upon injury suffered in the course -of his employment. The old theory of the law was that an injured employee might recover from an employer who was guilty of actual or imputed negligence, provided he himself was not negligent and had not'assumed the risk of suffering such injury. The new theory of'the law is that there should be at least a partial indemnity wherever- the casualty is incident to the employment — unless. the [528]*528casualty is the result of the wilful act of the injured employee. The old theory was. a by-product of the erroneous economic assumption that the wages of the workman were measurably determined by the dangers attendant upon the employment, so that the public ultimately bore, by way of increased price of the things produced by him, the burden which primarily rested upon the employee. The new theory emanates from a more consistent economic view that it is proper for the industry itself, as a part of the cost of production, to furnish relief to the incapacitated servant and to assume the burden of all industrial casualty to its employees. Indeed, it is now generally recognized that industrial risks are necessary accompaniments and incidental expenses of all industrial enterprises.

As already indicated, the injured employee’s right to such payment is not dependent upon his want of fault or upon his employer’s negligence. If the injury is suffered in the course of the employment and is not wilfully self-inflicted, payment must be made. In this respect it is simply insurance paid out of the fund created in whole or in part by the employer. The first Ohio act (102 O. L., 524-533) expressly stated (Section 18) that “the State Liability Board of Awards shall establish a state insurance fund from premiums paid thereto * * as herein provided.” The present act (103 O. L., 95) creates an industrial commission for the purpose of administering this “insurance fund.” As has been said of the English act (1897, 60 and 61 Viet., ch. 37), which is the prototype of our act, “the principle underlying the act imports into British law the novel doctrine that an employer of labor, apart from personal or constructive negligence, is a compulsory insurer, against accident, of the workmen employed by him.” Clerk & Lindsell, Torts, 4 Ed., 98. See also Dicey, Law and Pub. Opinion in Eng., 281, 283.

We have employed the word “indemnity” as measurably definitive of the amount paid to an injured workman. Even this term is not strictly accurate, for the fact that the amount to be paid under the act is determined according to an arbitrary scale and-that only partial wages are paid during incapacity, strength[529]*529ened by the analogy to life and accident insurance, would indicate that the payment is rather in the nature of a bonus than of an indemnity. XXVII H. L. R., 307-8. Therefore no remedy by subrogation can be given, unless such remedy is expressly created by statute. Interstate Telephone Company v. Public Service Electric Co., 90 Atl. (N. J.), 1062.

The validity of defendant’s claim depends, of course, entirely upon his thesis that there can be only one recovery for the alleged tort — that when settlement has been made with one of two joint or quasi joint tort feasors, the other is discharged from all liability. Unfortunately for defendant’s position, however, this contention begs the very question at issue. Decedent’s employer and the defendant were not joint tort feasors. The law required the employer to maintain insurance for decedent’s benefit. With this insurance defendant had absolutely nothing to do. It was paid to the decedent’s dependents solely because he met his death in the course of the employment, which was the risk insured against. The employer was guilty of no tort, and plaintiff, to justify her claim under the compensation act, was not required to make any of the allegations which usually characterize and are essential to a claim in tort. She did not have to allege or prove negligence on the part of her decedent’s employer, nor could payment be avoided by anything short of proof that the injury which caused the death was “purposely self-inflicted” (Section 1465-68). Full monetary compensation could not be recovered, nor was there any pretense that the amount actually paid covered the pecuniary loss suffered by the dependents of the decedent. The duty to make payment arose entirely outside of the law of torts. It was rather a legal obligation arising out of the contract of service (Interstate Telephone Company v. Public Service Electric Company, supra). The sum so paid bore no resemblance in any of its essential features to damages, and the right to recover can not be tested by any tort analogies. '

Indeed, it has been cogently contended by many authorities that such statutes as ours are not even an exercise of the general police power, but of the taxing power; that they have nothing to [530]

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Cite This Page — Counsel Stack

Bluebook (online)
18 Ohio N.P. (n.s.) 526, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kenning-v-interurban-railway-terminal-co-ohsuperctcinci-1915.