Kittredge v. City of Cincinnati

2 Ohio N.P. (n.s.) 6
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedMarch 15, 1904
StatusPublished

This text of 2 Ohio N.P. (n.s.) 6 (Kittredge v. City of Cincinnati) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kittredge v. City of Cincinnati, 2 Ohio N.P. (n.s.) 6 (Ohio Super. Ct. 1904).

Opinion

The plaintiff asks for a new trial on a number of grounds.

It is claimed that there was error in giving a part of the general charge of the court as to what would be actual notice to the city of the hole in the road. The court used the following language:

“Actual notice is where the city’s proper officers or agents have notice of the defect. Notice to a- police officer is sufficient if he knew of the hole sufficiently long before the áccident to report it, and if the police made it a custom to report defects in the streets to the department having the repair of streets in charge, and if such department made it a custom to receive such reports from the police.”

Counsel for plaintiff claims that there would be actual notice to the city if the policeman knew of the hole, and that the qualifications in the charge as to custom were erroneous and prejudicial. The court does not think that the charge was wrong; and even if it was, considering the testimony, the error was not prejudicial.

[8]*8' The question whether or not notice to a policeman is actual notice to the city has been raised so frequently in our courts that it is strange there is no Ohio decision settling the question; but counsel say there is not, and the court knows of none.

At the time this stallion was killed (1900) it was made the duty of the police of this city “to remove nuisances existing in public streets, roads,” etc., by Section 1878, Revised Statutes, and also Section 1934, Revised Statutes. A hole in the street is a nuisance (46 O. S., 442). It was made the duty of the city by Section 2640, Revised Statutes, to keep .the streets free from nuisance.

Now, were the police the agents of the city at that time to report holes in the streets? If so, were they the agents of the city for this purpose by virtue of some law, or by virtue merely of their office as policemen? The court thinks they were the agents of the city for this purpose by reason of a custom 'to use them as agents in this way, which custom, as will presently be pointed out, was established by the testimony in this ease, and it was upon this testimony that the charge given was based; but the court does not think they were agents of the city to take notice of holes in the street either because of any law or because of their mere office as policemen.

The city in the execution of its governmental powers is compelled by statute to have policemen, firemen, etc., but in appointing them the city is only carrying out a political duty, and they are not the agents of the city but of the state. Shearman & Redfield on Negligence, Section 291 (5th Ed.), with cases cited.

“Police officers can in no sense be regarded as servants or agents of the city. Their duties are of a public nature. Their appointment is devolved upon cities and towns by the Legislature as a convenient mode of exercising a function of government, but this does not render the ’cities or towns liable for their unlawful or negligent acts.” Bigelow, C. J., 82 Mass., 172.

At the time of this accident the appointment, regulation and government of the police force of the city of Cincinnati was vested in the mayor and board of commissioners appointed [9]*9by the governor of Ohio (Section 1870, Revised Statutes). The men were appointed by the mayor with the approval of the board (Section 1871, Revised Statutes); and the mayor had full control over the organization and discipline of the force (Section 1875, Revised Statutes). In case of emergency the mayor had the power to call out the whole force (Section 1877, Revised Statutes); and the specific duties of the mayor and the police in regard to preserving the public peace and safety were laid down in Section 1878, Revised Statutes. This latter section is the one referred to above, which requires the police, among other duties, to remove nuisances from the streets.

Under these statutes the commissioners and the maydr have the right to regulate the police and direct them in the discharge of their duties, but the city has no such power. It is true the mayor is a city official, but his management of the police is conferred upon him by statute, and he is not amenable to the city for any violation of his duty in this respect, nor could the city by ordinance direct him in his control of the police. The police commissioners are certainly not authorities of the city. They are a body of state officers, although they exercise authority within the city for the purpose of maintaining public peace and order (Altvater et al v. Mayor, etc., of Baltimore, 31 Md., 462). Until the city takes some action to make the police its agents they are the agents of the state only in carrying out the duties imposed by these statutes.

But the police may be the agents of the city as well as of the state, without doubt. The city may authorize them to act as its agents by an ordinance or by custom. No peace officer of whatever sort, however, is an agent of a city to notice a defect in a street merely by virtue of his office. There are no cases to support such a view.

That a city may make, the police its agents by an ordinance appears from Bowman v. Tripp, 14 R. I., 242, where to establish the negligence of the authorities of the city of Providence the plaintiff introduced in evidence the police regulations adopted by the town, which made it the duty of the police patrolmen to note and report without delay all obstructions in the streets.

[10]*10Again, custom may make the police the agents of the city -with regard to defects in the streets of the city to such an extent that notice to a policeman is notice to the city. Thus notice to a policeman of the defective condition of a sidewalk is notice to the city where the policemen have for several years been charged with the duty of reporting defects in the sidewalks by, writing in a book kept for such purpose, with the knowledge of the superintendent of streets, who resorted to such reports for information. City of Joliet v. Looney, 159 Ill., 471.

The authorities cited in support of the foregoing views have been found by the court in the pursuit of its own investigation of the question, and it is possible that a more exhaustive search would reveal additional authorities. Those relied upon have impressed the court as being sound, however.

Counsel for the ‘ plaintiff in support of their view that this charge of the court was error, have cited 91 N. Y., 144; 102 N. Y., 218; 152 N. Y., 222; 10 Col., 377, and 89 Mo., 209. The court finds a statement in Elliott on Roads and Streets, page 463, to the effect that “where the police are charged with the duty of removing obstructions from the streets, notice to the police on duty of an obstruction is sufficient”; and the author in support of this statement cites four of the above cases given by counsel for plaintiff, with the addition of one other ease, 100 N. Y., 15. From the force with which junior counsel for plaintiff has insisted upon the correctness of his view of this question, the court is inclined to conclude that these cases comprise about all, if not all, the decisions that can be found to substantiate his claim. The court has read all of these cases, and in its opinion not one of them supports the claim of counsel for plaintiff. Moreover, the assertion in Elliott that where the police are charged with the duty of removing obstructions from the streets notice to a policeman is notice to the city, is of no value unless we understand by whom

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Bluebook (online)
2 Ohio N.P. (n.s.) 6, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kittredge-v-city-of-cincinnati-ohctcomplhamilt-1904.