Kirk v. City of Cincinnati

25 Ohio N.P. (n.s.) 473, 1925 Ohio Misc. LEXIS 1468
CourtOhio Superior Court, Cincinnati
DecidedApril 25, 1925
StatusPublished

This text of 25 Ohio N.P. (n.s.) 473 (Kirk v. City of Cincinnati) 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
Kirk v. City of Cincinnati, 25 Ohio N.P. (n.s.) 473, 1925 Ohio Misc. LEXIS 1468 (Ohio Super. Ct. 1925).

Opinion

Marx, J.

In this case, the city of' Cincinnati stands convicted by the verdict of the jury and its own admissions of having built a trunk sewer known as Muddy Creek Sewer for the purpose of draining a thickly inhabited portion of Cincinnati and having dumped all of the sewage of this area into Muddy Creek. By its acts in so doing, the city of Cincinnati polluted and poisoned the previously pure and potable waters of that stream. No consent or rights were acquired from the property owners along the banks of such stream authorizing its pollution. The plaintiff is the owner of 805 acres of farm land on and adjacent to the banks of said stream. No compensation was paid to the plaintiff for the destruction of his property right to obtain pure water from this stream flowing through his land.

The plaintiff commenced this action to recover compensation in the amount of seven thousand dollars for the damage done to his property by the unlawful pollution of Muddy Creek by the defendant and for an injunction against a continuance of such nuisance.

Upon the trial of the case as an action at law for damages, the. jury found a verdict in favor of the plaintiff and assessed the damages at five thousand dollars. The defendant now asks that this verdict be set aside, and the plaintiffs ask for judgment on the verdict and for an injunction against the continuing damages.

The city defends upon the grounds that:

1. It is not liable for its acts.

2. That the plaintiffs are barred from maintaining this action by reason of having purchased their farm after the completion of the sewer; and,

3. That the plaintiffs and others contributed to the pollution complained of.

These points will be considered in their order.

[475]*4751. Upon its facts this case in indistinguishable from that of the City of Mansfield v. Balliett, 65 O. S., 451. In that case the riparian right to have a natural water course flow through one’s property undiminished in quantity or quality, is held to be a constitutional property right of which, the owner cannot be deprived without just compensation even though taken for a public use, and that any material interference with such right, is a taking of his property.

This conclusion is also supported by the following well considered eases: The C. & H. C & I. Co. v. Tucker, 48 O. S., 41; The City of Mansfield v. Bristor, 75 O. S., 270; Straight v. Hover, 79 O. S., 263.

2. The plaintiffs purchased their farm. in 1917. The city completed its sewer and began to dump sewage into Muddy Creek about 1911. The city claims that the purchase of the land by the plaintiffs after the creation of the nuisance bars their right to maintain this action. Upon this point, the court instructed the jury that the right to have Muddy Creek flow through the property in question in its undefiled and natural state was a property right incident to the soil and passed with a conveyance of the land to the plaintiffs who did not take cum onere, but acquired their property with its riparian rights, of which, the defendant could not deprive them without compensation.

This charge is fully supported by reason and authority. The general rule is stated in a discussion of defenses under the topic of Waters, 40 Cyc., 599-B, as follows:

“Defendant may set up in defense that he has in some manner, as by consent, acquiseenee, release, etc., acquired the right to do the acts complained of, or may interpose a plea of limitations or laches; but he cannot escape liability by setting up that plaintiff bought the property with knowledge of the existing conditions as to the pollution of the stream.” See also, 27 R. C. L., Article 12, at page 1071.

An exact case in point is, O’Brien v. City of St. Paul, 18 Minn., 176. In that case, damages and an injunction were granted against the city on account of its having emptied sewage [476]*476-into a natural watercourse to the .damage of the plaintiff. The court said in the fourth syllabus.

"It is not material that the sewer was built by the defendant more than six years prior to the commencement of this action, and has been used continuously by the defendant without objection from the former owners of the premises owned by the plaintiff, until the purchase thereof by the plaintiff, and that plaintiff purchased the premises with .full knowledge of the existence of the sewer. Nothing in any or all of these facts would change the character of the defendant’s act.”

Similar rulings were made in Mayor & Councilmen of Troy v. Coleman, 58 Ala., 570; Learned v. Castle, 78 Cal., 454; Alexander v. Kerr, 2 Rawles Rep., (Supreme Court of Pennsylvania), 82; Bly v. The Edison Electric Illuminating Co., 172 N. Y., 1.

Without exhausting the list, other cases supporting this rule, are: The Central Railroad v. English, 73 Ga., 366; Baltimore & Sparrows Point R. R. Co. v. Hackett, 87 Maryland, 224: McKee v. The St. Louis, Keokuk & Northwestern R. R. Co., 49 Missouri Appeals, 174; Oehler v. Levy, 234 Ill., 595; Townsend v. Bell, 62 Hunn., 306.

3. The city strongly urged that the pollution of Muddy Creek was contributed to by the plaintiffs and by the village of Cheviot. Whether pollution contributed by the plaintiffs to a stream already polluted by the defendants would constitute a complete bar to an action on their part for the pollution caused by the city, may well be doubted. In our opinion, the better rule is that contributory pollution, unless it goes to the extent of causing the condition complained of, is not a complete bar but may be considered in mitigation of damages. This view finds support in the Treatise on Nuisance, 20 R. C. L., Article 108, and in. Bowman v. Humphrey, 132 Iowa, 234. 109 N. W., 714, 6 L. R. A., (N. S.) 1111, the syllabus of which reads in part:

"In an action to recover damages for fouling a stream so as to constitute a nuisance, it is no defense that plaintiff’s own acts contributed to the injury.”

[477]*477In the opinion, a large number of eases are collected, and the L. R. A. annotator states that the authorities are practically uniform.

However, in view of some uncertainty as to the Ohio rule, caused by the unsupported case of Wheeler v. The Fischer Oil Co., 6 O. N. P., 309, this court gave the defendant a more liberal charge upon the subject of contributory pollution than the authorities generally warrant and charged the jury as follows:

“Obviously, if you find that the pollution and the nuisance of which the plaintiffs complain in this case is substantially and materially caused and created by their own acts in carrying filth or sewage and other befouling matter into this stream, then the plaintiffs, having created the conditions or having materially and substantially created the conditions of which they complain, are not entitled to recover anything by way of damages and in such case, a verdict should be for the plaintiff.

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Related

Bly v. Edison Electric Illuminating Co.
64 N.E. 745 (New York Court of Appeals, 1902)
Learned v. Castle
21 P. 11 (California Supreme Court, 1889)
Central Railroad v. English
73 Ga. 366 (Supreme Court of Georgia, 1884)
Mayor of Troy v. Coleman
58 Ala. 570 (Supreme Court of Alabama, 1877)
Reifsnyder v. Canton Fertilizer & Chemical Co.
9 Ohio App. 161 (Ohio Court of Appeals, 1918)
Oehler v. Levy
85 N.E. 271 (Illinois Supreme Court, 1908)
Bowman v. Humphrey
109 N.W. 714 (Supreme Court of Iowa, 1906)
Baltimore & Sparrows Point Railroad v. Hackett
39 A. 510 (Court of Appeals of Maryland, 1898)
O'Brien v. City of Saint Paul
18 Minn. 176 (Supreme Court of Minnesota, 1872)

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Bluebook (online)
25 Ohio N.P. (n.s.) 473, 1925 Ohio Misc. LEXIS 1468, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kirk-v-city-of-cincinnati-ohsuperctcinci-1925.