Loomis v. Toledo Railways & Light Co.

107 Ohio St. (N.S.) 161
CourtOhio Supreme Court
DecidedMarch 6, 1923
DocketNo. 17657
StatusPublished

This text of 107 Ohio St. (N.S.) 161 (Loomis v. Toledo Railways & Light Co.) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Loomis v. Toledo Railways & Light Co., 107 Ohio St. (N.S.) 161 (Ohio 1923).

Opinion

Jones, J.

This case involves the question whether the court should have applied the maxim res ipsa loquitur under the state of facts presented at the trial. This rule was invoked by the plaintiff below in his special request after argument, which was refused by the court. In their brief, counsel for plaintiff in error state that the principal question involved here is whether the “doctrine of res ipsa loquitur applies where the poles and wires of an electric company fall into the street and damage the property of a person lawfully traveling upon such public highway.” If this were the real question in the case, an affirmative answer would he required under the decision of this court in Cincinnati Traction Co. v. Holzenkamp, 74 Ohio St., 379, which held that the presumption of negligence arose where a trolley pole of an electric car fell upon a person standing in a public thoroughfare at the usual stopping place, and who was about to become a passenger. The solution of the question before us, however, depends not so much upon the case made in the petition as upon the case and facts presented at the trial. The real question presented is whether the plaintiff below was entitled to the application of the maxim res ipsa loquitur, where the proof offered tended to show at least as strong a probability that the injury [167]*167was caused by the act of God as that it was caused because of lack of due care on the part of the defendant.

The gravamen of the plaintiff’s charge was negligence in maintaining poles that were rotten and decayed and not of sufficient strength to support the wires thereon. The answer of the defendant stated that the poles and wires fell because of a severe and extraordinary storm, amounting to a vis major> which the plaintiff denied. In fact these were the two main issues upon which the case went to trial. The witness Currier, who was in charge of the weather bureau, testified that at,this particular time the wind attained a velocity of fifty-one miles an hour in Toledo, and that within the next hour had attained a velocity of sixty miles per hour. This was a witness offered by the plaintiff. When asked whether this was a usual storm, or one above the ordinary, he said ‘ ‘it was above the ordinary. ’ ’ Evidence offered by the defendant later corroborated and supplemented this testimony by further proof tending to show that the injury was caused by an act of God.

In view of the case thus presented, was the plaintiff below entitled to the instruction as requested, that a presumption of negligence arose by proof “that a pole or poles of the defendant fell and injured his ear on the afternoon of the day alleged in the petition?” In negligence cases the rule is general that specific acts of negligence must be proved by the plaintiff. Exceptions have been made in some cases, and affirmative proof of negligence is dispensed with where the physical facts producing injury justify the court and jury in inferring negli-. [168]*168gence as a proximate cause of the accident. In snch cases the maxim, res ipsa loquitur, applies. In the courts of this country it is generally applied in cases where the relation of carrier and passenger exist and the accident arises “from abnormal condition in the department of actual transportation.” (2 Thomas on Negligence [2 ed.], 1095.) As stated by the same author, the maxim is also applied “Where the injury arises from some condition or event, that is in its very nature so obviously destructive of the safety of person or property, and is so tortious in its quality, as in the first instance, at least to permit no inference, save that of negligence on the part of the person in the control of the injurious agency.”

This application of the rule has been approved in the various textbooks, and by the case of Benedict v. Potts, 88 Md., 52, 56. In cases where the maxim is applied it easts upon the defendant the duty of explaining the cause of the injury. However, it never has the effect of shifting the burden of proof. “Res ipsa loquitur, means that the facts of the occurrence warrant an inference of negligence, not that they compel such an inference, nor does res ipsa loquitur convert the defendant’s general issue into an affirmative defense.” Sweeney v. Erving, 228 U. S., 233, and Klunk v. H. V. Ry. Co., 74 Ohio St., 125.

Whether the testimony touching the cause of the injury is of such evidentiary value as to raise the presumption of negligence, under the maxim res ipsa loquitur, is for the court. (4 Wigmore on Evidence, Section 2507 et seq.) The lord chancellor, in Metropolitan Ry. Co. v. Jackson, 3 L. R. App. Cases, 193, at page 197, thus stated the rule which is gen[169]*169erally supported: “The Judge has to say whether any facts have been established by the evidence from which negligence may be reasonably inferred; the jurors have to say whether, from those facts, when submitted to them, negligence ought to be inferred

The rule is a rule of evidence, and arises from probabilities reasonably inferred from the character of the accident itself. It rests upon the presumption that when an instrumentality under the control of the defendant causes the injury, and such injuries do not ordinarily happen in the course of events if due care is exercised, then a presumption arises, in the absence of explanation by the defendant, that the accident was caused by want of care. Having this rule and its application in view, how can it be said, when the proof offered tends to show that the accident was caused by another than the defendant, that a conclusive presumption arises, without other specific proof, that the accident was caused by the defendant? Necessarily the reason for the rule fails. The author in 1 Sherman & Bedfield on Negligence (6 ed.), Section 58b, discussing the doctrine of res ipsa loquitur, says: “The causative force of the injury must be shown to be controlled by the defendant; it must also appear that there was no other equally efficient proximate cause. If from the nature of the event causing the injury an enquiry naturally arises which one of two or more persons, acting independently, is responsible; or, if it appear that the injury was proximately caused by the independent acts of two or more persons, the application of the maxim is excluded by its terms.”

“The maxim res ipsa loquitur relates merely to negligence prima facie and is available without ex-[170]*170eluding all other possibilities, but it does not apply where there is direct evidence as to the cause, or where the facts are such that an inference that the accident was due to a cause other than defendant’s negligence could be drawn as reasonably as that it was due to his negligence.” 29 Cyc., 624.

“Where all the facts connected with the accident fail to point to the negligence of the defendant as the proximate cause of the injury, but show a state of affairs from which an inference could as reasonably be drawn that the accident was due to a cause or causes other than the negligent act of defendant, the plaintiff cannot rely upon mere proof of the surrounding facts and circumstances, nor is defendant called upon to explain the cause of the accident or purge itself of the inferential negligence. The doctrine of res ipsa loquitur does not apply in such case.” McGrath v. St. Louis Transit Co., 197 Mo., 97.

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Related

Sweeney v. Erving
228 U.S. 233 (Supreme Court, 1913)
Searles v. . Manhattan Railway Company
5 N.E. 66 (New York Court of Appeals, 1886)
Wadsworth v. Boston Elevated Railway Co.
66 N.E. 421 (Massachusetts Supreme Judicial Court, 1903)
Chicago Union Traction Co. v. Crosby
109 Ill. App. 644 (Appellate Court of Illinois, 1903)
St. Louis & San Francisco Railroad v. Burrows
61 P. 439 (Supreme Court of Kansas, 1900)
Benedick v. Potts
41 L.R.A. 478 (Court of Appeals of Maryland, 1898)
McGrath v. St. Louis Transit Co.
94 S.W. 872 (Supreme Court of Missouri, 1906)

Cite This Page — Counsel Stack

Bluebook (online)
107 Ohio St. (N.S.) 161, Counsel Stack Legal Research, https://law.counselstack.com/opinion/loomis-v-toledo-railways-light-co-ohio-1923.