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Cornell Law Schou! Library
ii
Eggleston on Damages
A TREATISE
SONS
THE LAW OF DAMAGES
By WILLIAM EGGLESTON,
Author of ‘‘A Tre: on tie Commi issioners.’
PUBLISHED BY
HEBB & GOODWIN, TERRE HAUTE.
1880.
G4Y/I46
Entered according to act of Congress in the year 1880,
By WILLIAM EGGLESTON,
In the office of the Librarian of Congress at Washington, D. C.
PREFACE.
In submitting this work to the Profession, I feel great
anxiety as'to its merit as well as to its reception by the
public. The question of Damages is one of vast variety and
extent, being generally the sole aim and object in the prose-
cution of each legal proceeding, so that in the discussion of
the different questions arising under this branch of the law, I
have been compelled in many instances to examine primary
principles, and to comment on the law governing the class of
cases under consideration. I have been much embarrassed in
my effort to present the law on the question of Damages in a
clear and concise manner, owing to the conflict of authorities
and the variety of rules that exist in the different States.
But I have endeavored to harmonize these different rules and
discuss them together; and where this could not be successfully
done, I have given them:in full and,commented on the justice
and propriety of éach. It is a fact well known to every law
student that the field of legal science has, within the last half
iv LAW OF DAMAGES.
century, been greatly expanded by scientific discoveries, the
growth of several commercial interests, and the creation of
many statutory rights. I have attempted to notice in detail
all the questions that have, or may hereafter arise, in refer-
ence to the law of Damages growing out of the enlargement of
the field of jurisprudence, and endeavored to incorporate into
the texts some of the leading rules that should govern courts
and juries in the assessment of Damages, and to show the
reasons upon which they are founded. In order to accomplish
this task, I have gone through an examination of authorities
that cost me much time and labor. It has been my aim to
furnish the student and practitioner with a practical treatise,
based upon the most recent authorities; and I indulge the
hope that my effort has not been in vain.
WILLIAM EGGLESTON.
TERRE HAUTE, INDIANA, June 18, 1880,
Index to Authorities Cited.
i Section
A.T. &S. F.R. R. Co. v. Stand-
ford 5, 196, 200, 202
Atchison R. Co vy. Sanford 6
Allison v. Chandle 6
Adams Ex Co v. Egbert 10, 11
Anthony v. Gilbert 13
Achison v. Erie R. R Co. 14
Atlanta E. R. Co. v. Dunn 14
Aclon v. Blundell 20
Anthony v. Gilbert 41
Austin v. Wilson 44
Adam v. Wagoner 59
Adams v. Freeman 60
Andrews v. Asky 87
Akin v Newell 89
Anthony v. Gllbert 96
Ainsly v. Medly . 98, 99, 110
Aortson v. Ridgway 104
Arbuckle v. Taylor 137
Ammerman v. Crosley 145
Alabama v. The Gamecock 170
Austin v. Steamboat Co. 176
Amick v. O’Hara 181
Albertson v. Chandle 193
Allen v. Atlanta Street R. Co. 223
Armstrong v. Moranda 230
Armstrong v. Pierson 234
Alderman v. French 234, 307
Andrews v. Durant 239
Anger v. T. P. M. Co., 240
Allen v. Fox 254, 256
Ableman v. Booth 262
Allen v. Jones 263
A.S.R R. Co. v. Dayton 264
Section
Airie v. Sedgwick 276
Arnold v. Commonwealth 279
Ackley v. Chester 280
Alexander v. Helber 281
Ash v. White 285
Amoskeag Mi. Co. v. Goodale 290
Adons v. Ellis 290
*, Addison v. Hock 297
Amola v. Foot 297
Allen v. McCorkly 298
Atkins v. Chilson 300
Anderson v. Johns 306
Austin v. Hanchette 307
Alderman v. French 307
Allen v. Suydam 309
Atchison v. Baker 327
Armstrong v. Purey 329
Andrew v. Pearce 350
Anderson v. Davidson 353
Arrigoni v. Johnson 3A3
Ady v. Allen 355
Asland F Ins Co. v. Hislayes 692
Asland F. Ins. Co. v. Drenchler
Mut. Fire 693
Abbott v. Gatch 474
Ashe v. DeRosett A474
Adams Ex. Co. v. Egbert 474, 526.
Allen v. Jenis 48 0, 481
Allen v. Kibber 482, 486, 495
Allen y. McCeblen 489
Anderson v. Foresman 506
Am. Ex. Co v. Smith 514
Adams Ex. Co. v. Daniel 515
Ala. & Tenn. R. R. Co. v. Kidd 515
vi LAW OF DAMAGES.
Section
Astly v. Weldon 550, 551, 552, 557
Abrams v. Kounts 555
Alkyns v. Kenner 560, 561
Andrews v. Glenville 572
Aldrich v. Reynols 572
Allen v. Brown 574
Allen v. Fox 580
Adams v. Adams 580
Averall v. Wade 583
Andenread v. M. M.In. Co. 588
American Ins Co. v. Ogden 590
Angelrod v. Delaware Ins. Co 696
Atwood v. Un. Mut. Ins. Co. 699.
Ashland Ins. Co. v. Smith 699
Allen v. Suydam 706, 708
Adams v. The Med. R. Co. 711
Armitage v. Hale 727
Anderson v. Tarpley 727
Atwood y. Gilapsie 727
Allen v. Anderson 361
Adamson v. Rose 361
Adams v. McMullen 362
Alna v. Plumer 370.
Adams Ex. Co. v. Egbert 872
Arden v. Pullen 376
Adair v. Bagley 379, 382
Allen vy. Bicknell 383
Allen v. Culver 384
Andrews v. Pond 398, 412, 413
Arnold v. Potter 414
Albert v. Citizens’ Bank 420
Adam v. Beard 429
Andrews v. Jones 431
Andre v. Dixon 434
Abell v. Alexander 435
Andrews v. Mecmett 435
Alesworth v Brown 437, 440
American Bank v. Doolittle 438
Allison v. Thomas 440
Agnew v. Meritt 441
Alexander v. Bank of Com’th 442
Adams y. Roane 443
Apgar v. Hiller 444
Armstrong vy. Gilchrist 445
Andrews v. Kneeland 453
Armstrong v. Perr 458
Arnold v. Suf. Bk 467, 468, 475, 479
Aurlen v. Hilliers 730
B.
Boyd v. Watt, 585
Bramhall v. Sun, 587
Bramhall v. Sun. Mut. Ins. Co. 587
Bradlie v. Maryland Ins. Co., 588
Baker v. Manf. Ins. Co., 589
Burgess v. Alliance Ins.Co., 691
Section
It. Fire Ins. Co. v. Long, 696
ate Mont. Fire Ins. Co., 696
Blaeser v. Milw. Mut. Ins.Co., 697
Blot v. Boxcean, 706 707
Bell v. Cunningham, 708 709
Beal v. Railway Co., 711
Bartlett v. Merritt, 711
Bennett «. Acock, 715
Brown v. Tanner, 716
Bodwell v. Osgood 720
Belknap v. R. BR. Co., 722
Blunt v. Little, 727
Brown y. Seymour, 730
Boyd v. Fett, 474
Baldwin v. Bennett, _ 474
Booth v. Spagler D. Mill Co., 474
Booker v- Goldsborough, 474
Begdensberg v Welch, 4717
Barries v. Hutchinson, 477
Barnard v. Hamilton, 479
Beard v. Sloan, 480
Bement v. Smith, 481
Ballantine v. Robinson, 481
Baker v. Hoyt, 482
Britton v. Turner, 482
Bishop v- Price, 482, 489, 495
Bingham v. Howley, 484, 491, 498
Boust v. Frith, 486
Britton v. Turner, 488
Bracket v. Morris, 489
Baker v. Troy Rutland R. Co., 489
Bradman v. Keeler, 495
Brown v. Foster, 499
Blossom v. Ball, 509
Bohannon vy. Springfield, 501
Brand v. Troy, 503
Brown v. Lynn, 503
Ball v. Lyng, 504
Burns v. Spear, 504
Barnler v. Neye, 504
Baily v. New, 443
Bishop v. Williams, 444
Butts v. Dean, 444
Benjamin v. Hillard, 447, 448
Brown v. Edgerton, 450, 457, 463
Brenton v Davis, 450
Bradford v. Bush, 450
Brown v. Stevens, 450
Bardry v. Foster, 451
Buckingham v. Goddard, 452
Butler v. Tuits, 452
Beebe v. Robert, 453
Boorman v. Jenks, 453
Bradford v. Manly, 458
Bower v. Lewis, 453
Burton v. Youn: 454
Blasdael v. Babcock, 458
INDEX TO AUTHORITIES CITED. vii
Section Section
Bent v. Denny 458 | Brown v. Maxwell 175
Booker v. Goldsborough, 464 | Beswigv. N. Y.C.R.R.Co. 176
Bridge v. Wain. 464 | Butterfield v. West. R. R. Co. 176
Barrikins v. Beav ens, 466 | Bellef. R. R Co. v. Hunt 176
Billings v. Vanderbeck 467, 475 | Brown v.H.&St.J.R.Co. 180, 182
Bartlett v. Blanchard 467, 475 | Bright v Gardner 180
Barnard v. Conyer 467, 475 | Baltimore & Ohio R. R. Co. v.
Beckel v. Colton 469, 476 State 180, 181, 182, 188
Baldwin v. Nichols 469 | Bird v. Holbrook 180
Booth v. The Spuyten Dunill Burdge vy Gardner 182
Rolling Mill Co. 470 | Baxter v. Troy & Boston Co. 183
Barries v. Hutchinson 471, 472 | Burke v. Strain 329
Barker v. Savage 183 | Burton v. McCally 330
Burke v. Broadway Co. 186 | Birch y. Merrick 330
Berger v. Gardner 188 | Bostwick v. Williams 336
Brown v Southberr 188 | Burk et al v. Clement 337
Bellef. R. R Co. v — 188 | Burton v. Reeds 337
Birmingham v. Dorer 189 | Bickford v. Page 337
Blyth v. Topham 192 | Bonta v. Miller 337
Bush v. Brainard 192 | Brant v. Foster 337
Burdock#. Worrell 193 | Blossom v. Knox 337
Butler v. Kent 193 | Biglow v Jones 342
Blake v. Midland R. Co. 208, 220 | Bond v. McZuattlebaum. 346
Barksley v. Swan 203 | Backus v. McCoy 347
Balto. R. R. Co. v. Quigley 204 | Baxter v. Bredbuty 349, 350, 858
Baker v. Draker 205 | Barber v. Coburt
Ballou v. Farmer 207 | Blanchard v. Brooks 350
Baker v. Bolton 208 | Barlow v. Morris 350
Butler v. Steambt Milwaukee 215 | Bing v. Haven 350
Balto. R. Co v. Kelly 223 | Bean v. Mayor 353
Bell v. Wooten 223 | Brooks v. Moody 358, 354
Baily v. Railroad Co 224 | Baldwin vy. Munn 353, 361
Belknap v. Boston, etc. R. Co. 224 | Barker v Hobbs : 353
Baily v. Chicago R. R Co. 224 | Bachelder v. Sturgis 354
Balto etc. R. R. Co. v. Wright- Brown v. Broadhead 354
man 226, 227 | Barrett v Porter 355
Bodwell v. Osgood 231 -| Butler v. Yiel 355
Belier v. Mit 234 | Beach v. Miller 855.
Bodwell v. Swan 234 | Barlow v. McKinly 355, 856
Beals v. Holmes Ins. 694 | Buller v. Runnels 297
Bacon v. Town 151 | Brakely v. Sharp 297
Bamford v. Turley 155 | Bennett v. Whitney 297
Barclay v. Commonwealth 155 | Brown v Owens 297
Body v. Weeks 158 | Billinger v N.Y. etc R.R Co, 297
Baugh v. The State 158 | Bowman v. Teal 805
Bigelow v. Hartf Bridge Co. 158 | Butt v. Gould 306
Barnard v. Conn. R. R. Co. 159 | Burnon v Lyden 307
Blunt v. McCormick 159 | Bodwell v Swan 307
Battishell v. Reed 159 | Boice v. McAllister 307
Barr v. Hoffman 159 | Bradly v. Gibson 307
Brozzi v. Harris 161, 162 | Bevinsv. Stokes 307
Burkly v. Lenard 161 | Budgeman v. Hopkins 307
Brill v. Brill 163 | Buck v. Rhoads 309
Butterfield v. Foster 175 | Bonlor v. Kelloge 312
Brooks v. Buffalo k. R. Co. 175 | Burnett v. Simpkins 312
Button, admr v. Hudson R. R. Bennet v. Smith- 317
Co. 175, 176, 177 | Bridge v. Grand J. R. Co. 319
vili
Section
Burts v. Thompson 321
Blattmacher v. Saal 322, 328
Balda v. Stratton 323
Burham v. Cornell 323
Buy v. Dontz 325
Baly v. Stratton 325
Butler v. McCauley 325
Butler v. Esphmer 328
Bell v. Eaton 328
Boynton v. Kellog 329
Burgess v. Alliance Ins Co. 691
Burgess v. Burgess 274
Boardman v. M. B Co. 274
Burnett v. Pharlan 275
Blackfield v. Payne 275
Bullett v. Clement 277
Burly v. Bethim 277
Burnard v Huffman 277
Blood v. Sayer 278
Burton v. Fulton 279
Bowman v. Crowell 279
Bickford v. Hood 279
Barrett v. Reed 279
Benott v. Miller 284
Bagby v. Harrass 285
Brown v. Davis 285
Bond v. Hilton 285
Burnap v. Wight 289
Bank v. Tencka 890
Bassett v. Saulsberry Mnf. Co. 290
Brown v. Watson 290
Burdon v. Mayor of Mobile 290, 297
Brown v. Price 290
Bowen v. Emerson 290
Bliss v. Kennedy 294, 297
Brown v. Brown 297
Bear Riv. Auben W. & M. Co.
v. York Co 297
Brown v. Smith 297
Blanchard v. Baker 297
Burns v. Webb 234
Bisbee v. Shoen 234
Barnes v. McCrete 235
Bell v. Farnsworth 236
By. R. v. Monahan 236
Bradley v. Heath 236
Bucher v. Dennison 239
Brisby v. Kendall 239
Baker v. Drake 242, 245
Brown v. Saxe 244
Betts v. Lee 244
Barker v. Wheeler 244, 249
Bizee v. Mayber 245
Bennett v. Lockw’d 245,257,310,319
Bickell v. Colton 247
Backenstor v Stahur 249
Bake: v. Freeman 281
LAW OF DAMAGES.
Section
Bedo v. Mut. Sav. Inst. 250
Butler v. Mishering 256
Blackwell v. Action 256
Barthol v. Fox 256
Butler v. Silliman ah
Beekman v. Saratoga
Br’klyn Park Co. v. Armstrong 263
Brown v. Beat 264
Boston RB. R. le: v. Lee 264
Buck v. Hermance 269
Blanchford v. Warner 269
Burdell v. Denning 270
Birny v. N. Y. & W. Tel. Co 536
Bery v. Dunill 540
Blanchard v. Ely 540
Bagby v. Peddice 550, 555, 559
Bristol R R. Co v. Collins 547
Brown v. Maulsby 551, 555
Barton v. Glover 551
Bruster v. Egly 503
Billingsly v. Dean 555
Bary v. Ambrose 555
Burrage v. Crump 500
Belts v. Kurch 597
Baird v. Tolliver 559
Brainard v. Jones 565, 566
Braingrive v. Perrott 965
Bennett v. Brown 568
Brehens v. McKenzie 572
Brown v. Jones 573, o74
Bergen v. Share avd
Brown v. Tyler 574
Boles v. Patton 580
Brewster v. Silliman 580
Bomby v. Gibbs 580
Butler v. Mechring 581
Banks v. Hallon 581
Blanchard v. Eling 581
Booth v. Clark 582
Baker v. Admr. of Bocus 582
Brown v. Cook 505
Bland v. Normuck 506
Beardsley v. Richardson 506
Beeman v. Lawton 507
Brown v. Runnolt 508
Bromwell v. Hankins 509
Bamfield v. Whipple 510
Buford v. Tucker 510
Bansmer v. I W.R.R. Co. 512
Burton v. Wilkinson 512
Bisselv. N.Y.C R.Co. 518, 514
Boyce v Anderson 514
Both v. Buffalo 515
Boarne v. Gatlif 515
Blumenthal v. Branard 515
Barcla v Clyde 515
Bansemer et al v. T.& W.R.Co. 517
INDEX TO AUTHORITIES CITED.
Section
Bracket 1. McNair 519
Boggs v. N. Y.C. R. R. Co. 521
Bliven v. Hudson R. &.R. Co. 525
Burton v. Wilkinson 525
Bourman v. Teall 526
Baldwin v. U.S. Tel Co. 531, 588
Bowen v. Lake E Tel Co. 531, 539
Brya.t v. American Telegraph
Co. 5381, 535, 539, 546
Breen & M. V.v U.S. TL Co 581
Bering v.N. Y.& W.U.TL Co. 533
Beese v. U.S. Tel. Co. 585, 536
Barnwell v. Mitchell, 428
Bangor Bank v. Hook, 429
Baker v. Martin, 429
Black v. Wilson 429
Babcock v Steadman 433
Blackwell v. State 434
Bowan v. Houk 435
Bank v. Mallet 435
Bonitler v. Stubbs 436
Balesan v. Gosling 436
Bell v. Manning 436
Buily v. Berry 437, 488 440
Brown v Marsh 436
Bronson v. Fitzhugh 437
Burke v. Noble 438
Brown v. Ayer 439
Bangs v. Sirong 440
Brown v. Exers of Riggins 440
Bay v. Talmuge 440
Bank of Hibion v. Burns 440
Burns v. Coats 440
Bank v. Fordice 442
Baker v. Briggs 442
Bolton v. Landy 443
Baker v. Kellogg 443
Bank v. Munford 443
Brinkerhotff v Phelps 307
Blackwell v Lawrence 361
Bain v. Fothergill 362, 365
Baldwin v. Munn 363
Barn y. Cress 365
Buchlyv. Davison 365
Blackwell v. oard of Justices 369
Boardman v. Keeler 370°
Barnham v. Nichols 370
Redall v. Reed 376
Benden v. Manning 382
Burling v. Reed 383
Brown v. Cram 383
Bullock v. Dommitt 383
Bracknock Can.Co v.Pritchard 584
Beal v. Sanders 384
brown v. Crump 384
Bryan v. Fisher 385
Birch v. Parker 885
ix
*
Section
Bronson v. Rhodes 408, 405
Kank of State v. Burton 407
Bigler v. Wall 408
Butts v. Olds 414
Brooks v. Hubbard 418
Baker v. Mair 418
Ballard v. Webster 422
Bank of Illinois v. Brady 424
Brown v. Davis 427
Brooks v Buffalo R. Co. 8
futton admrv.Hud.RR.Co. 8
Brown v. Maxwell 8
Blanchard v Eli 10
Bastron v. Stone 13
Booth v. Smith 13
Benson v. Green 13
Buckly v. Knapp 13
Biszer vy Maybell 14
Boynton v. Willard 17
Brown v. Roberts 18
Bockhoun v. Brown 18
Brown v. Allen Zi
Beach v. Fulton Bank 22
Brown v. Perkins 23
Beach v. Hotchkiss 23
Bangor Bank v. Treat 23
Ballen v. Bryant 26, 29
Bunon v. Edwards 28
Bird v. Dennison 30
Bocegirde v. Oxford 41
Beasman v. Carington 42
Baltimore v. Blacker 48, 53
Bell v. Marion 48, 53
Butler v. Muscer 44
Band v. Railroad : 46
Balt & O. R Co. v. Blacker 47
iassv. G. & N. W. R. Co. 48
Blyth v. Thompkins 95
Buchabor v. Slegman 96
Brown v. Carady 96
Bishop v. Coffett 98
Burson v Lock 99
Bell v. Henderson 100
Bowman v. Caruthers 102, 106
Barnett v. Stanton 104
Barton v. Simmons 107
Bellamy v. Sabine 109
Brooks v. Riding 110
Burrows v. Lock 110
Bradley v. Rea 113
Boatman v. Smith 116
Barnes v. Duffy 119
Bango v. Smith 119
Brown v. Coblaugh 120
Brown v. Wase 120
Burton v. Calaway 122
Bryan v. Gidden 127
x LAW OF DAMAGES.
Section
Berry v. Fletcher 128
Bement v. Thompson 128.
Bacon v. Towne 136, 145
Barron v. Mason 136, 150
Bell v. Graham 137, 146
Barnes v. Cress 146
Blizzard v. Hayes 149
Beal v. Robinson 151
Barber v. Kallborn 52
Banon v. Balto. & O. 54, 67
Burns v. Burk 55
Blackburn v. Mann 55, 321
Busket v. Lonato 56
Brown v. Swinford 57
Bauller v. Clark 59
Bell v. Hornsley 59
Barry v. Engles 62
Buller v. Gould 62, 63
Berchard v. Booth 69
Bowen v. Collin 71
Bartelet v. Henn 75
Bowers v. Vanwinkle 77
Barker v. Masley 79
Bamfield v. McCrary 81, 82
Bales v. Hill 82
Bennett v. Smith 82, 317
Bromley v. Wall 82
Ball v. Bruce : 88
Bartley v. Ruthnyer 88
Bagly v. Decker 88
Baughton v. Jackson 93
Baz. v. Tate 93
Bock v Stimpson 98
Bonesteel v. Bonesteel 94, 95
Bliss v. Thompson 94, 95
C.
Cincin & Chig. R. Co. v. Rogers, 6
Clark v. Morrlgha 6
Cleveland R. Co. v. Ferry, 8
Clark v. Kemis 8
Clark v. Bales 13
Church v. Beach 13
Chicago R. R. Co. v. Flog 13
Cochran v. Miller 13
Childs v. Drake 13
Chopper v. N. O. R. R. Co. 13
Colstead v. Cleveland 19
Clatfield v. Wilson 21
Curtin v. Patten 21
Clarke v. Allen 23
Conklin v. Thurston ‘23
Cromwell v. Wilkinson 28
Coffin v. Barthmoth 28
Churchill v, Watson 41
Cleghorn v. N. W &e. R. 42, 51
Section
Cook v. Ellis 44
Codwell v. N. J. Straw BCo. 45
Croft v. Allison : 46
CG. & BR. & St. RB. Co. v. McKeen 47
GC. R. IL & P.R Co. v. Harris 47
Collins v. Mack 51
Cadwell v. Steamboat Co. 54
Cochran v Miller __ oF
Coon v McLaughlin 57, 58
Cox v. Vanderbleed 60, 61, 68, 96
Cox v. Whitney 62
Comwlth v. Elliuger 65, 68
Curtis v. Casson 65
Cushman v. Ryan. 66
Cooper v McJunkin 72
Chambers v Caulfield 75
Cook v. State of Georgia 75
Catherwood v. Carlton 76
Codington v. Codington 77
Conway v. Nichols 78
Clouser v. Clapper 79, 84
Cockun v. Anman 80
Champner v. Peck 81
Colman y. Ballard 356
Coleraft v. Lad. Harbaugh 86
Colter v. Lower 89
Coen v. Fuckner 91
Cook v. Neithercote 91
Coupey v Henley O41
Coffin v. Vincent 93
Carpenter v. Pocker 97, 808
Cromwell v. Clifford 100
Clem v. Newcastle R. R: Co. 100
Colley v. Gadsden 102
Craig v. Ward 103
Cooper v. Vanermy 103
Coats v. Nickels 731
Coplen v. Phenix Ins. 691
Cross v. Peters 103
Cain v. Gurther 106, 107
Chandle v. Lonpus 106
Compart v. Hedges _ 107
Colson v. Smith 108
Cooley v. Hampton 108
Cooley v. Harper 108
Conner v. Henderson 108
Colville v. Besly 109
Cabot v. Christie 111
Car v. Moore 111, 116
Carter v. Binigen 113
Case v. Walcott 117
Crenshaw v. Moore 120
Cannon v. King 120
Cole v. Drew 122
Chamberlain v. Enfield 122
Clark v. Crinth 122
Connell v. Emric
123
INDEX TO AUTHORITIES CITED.
Section
C.R R. Co. v. Finegan 124
Cushen v Longfellow 128
Chamberlain v. Collisan 132
Cecel v Clark 136
Calboness v. Martin 137
Comwlth v Snelling 138, 146, 148
Chapman vy Wood 147
Closson v. Stapple 150
Comwlth v.SennetsB & Co. 692
Chapman v. Pickersville 150
Cooper v. Watson 151
Cooper v. Waldron 152
Cupley v. G. & B.S. M Co. 152
Call v. Buttrick 153
Cox v. Burbridge 162
Colgrove v. R. R. 172
Collins v. Hill 172
Cleveland R. R. v. Ferry 172
Clarke v. Kerman 175
Chicago & Miss. v. Parker 175
Cummings v. Spruce 176
C. &c. R. R. v. Crawford 176,
181, 183
Clark v. Kirwan 176
Chicago R. R. v Still 177
Cleander R_ R. v. Elliott 178
Chicago R. R. v. « lark 178
Cin. « Mart R.R.v Eaton 179
Cook v. Champlaid Trans. Co 181
Cotton v. Com. bench 183
Callahan v. ‘ ean 185
Chicago v. Starr 185
Chicago R. R. v. Denny 188
Chicago v. Carr 193
Samev. Hesing 193, 226
Cruft v. Newark R. R. 198, 194
Curtis v. Rochester 202
Canning v. Williamstown 203,
207, 220
Cadwell v. Murphy 203
Cox v. Vanderleed 203
Cents v. Roch. etal R Co. 207 *
Conner v. Weston 207
Cary v. Berkshire 208
Cress v. Guthrey 209
Chicago v. Mayor 220
Chicago etc. R Co v. Morris 220
Clev. & R. Co. v. Rowan 220, 223
Conant vy. Griffin 220, 228
Condon v. G. & C.R. R.Co. 228
Chicago v. Sholten 223
Condo v. G.S. R. R. Co. 223,
‘ 224, 227, 228
Chicago R. R. Co. v. Bayfield
224, 226, 227
Chicago v. Powers 224
‘Commonwealth vy. Clapp 230
z
xi
Section
Cornwall v. Richardson 234
Chubb v. Gill 234
Caulkins v. Sumner 235
Cooper v. Chitty 239
Caster v. Freeland . 239
Cook v. Loomis 239
Culler v. Farring 239
Chase v. Munroe 239
Carrier v Minshall 239
Ching v Vial 239
Chambers v. Shaw 239, 240
Conner v. Vall 240
Ceeency v. Wall 240
Chi. & Dock Co. v. Dunlap 242
Chipan v Hibberd 246, 248
Cox y. England 246, 248, 313
Clapp v Walters 256
Chessom v. Lancool 256, 260
Conoway v. Flint 256, 286
Chi. R. Co v. Shultz 256
Chapman v. Chi. R Co. 256
Sooper v. Williams 263
Craig v Mayor 263
Casto v. St. Paul R. Co. 264
Carter v. Baker 269
Cristie v. Murphy 273
Coruw v. Derby 273
Clark v Clark 274
Coats v Holbrook 274
Cabel v. Cooper 278
Clark v. Miller 279
Clark v. Smith 279
Clark v Hallock 281
Cox v. Sullivan 282
Conger v. Weaver 286
Champion v. Vincent 287
Cory v. Silcox 288, 289, 290
Cornly v. Davieson 289
Cox vy. Sprigg 290
Copeland v. Copeland 290
Collier v. Gamble 290
Conroy v. Flint 290, 309
Clinton v. Myers 293
Chase v.N. Y.C.R Co 296, 297
. Curtis v. Kiesler 297
Coen v. White 297
Cottod v. Pocasset Mfg. Co. 297
Chambell v. Smith 297
Carbert y. Auburn Gas L. Co. 297
Clatfield v. Wilson 297
Collier v. Pierce .800
Cherry v. Stiene 300
Carriage v. Dee 301
Casner v. Sitker 305, 306
Chill v. Horner 306
Calaway v. Middleton 307
Case v. Marks 7, 311
xii
Section
Case v. Marks 307, 313
Clark v. Massiglia 310, 315
Coleman v. White 82, 84, 311
Clause v. Clapper 311
Chipman v. Hibbard 313
Costigan v. M. & H. R. 317
Colts v. McKinney 322, 324, 329
Clark v. Pendleton 322
Coil v. Wallace 323
Conway v. Shelton 823
Chesby v. Chesby 325
Clements v. Moore 328 .
Cow vy. Wilson 329
Comnwlth v. Knowlton 335
C., P. & Ft W. R. v. Pearce 337
Casewell v. Wendell 337
Cummins v. Kennedy 337
Cox v. Henry 848, 358, 362
Connell v Jackson 349
Clark v Swift 350
Chapman v. Holmes 350
Cumuniings v. Little 353-4
Clappell v. Bull 354
Cain v. Allen 354
Cuther v. Russell 355
Church v Higgin 855
Cady v. Allen 356
Conger v. Weaver 361-5
Clowny v. Crogham 361
Combs v. Tarlton 361
Cockcroft v. N. Y. & H. R. R.
361, 363, 364. 365
Case v. Wolcott 363, 367
Cook v. Booth 376
Connell v. Lumsby 380
Curtin v. Galvier 383
Cronin v. Hoover 385
Cook v. Litchfield 395
Crysler v. Renos 405
Carpenter v. Atherton * 405
Clark v. Nevada L. & M. Co. 405
Cushing v. Wells 407
Catlin v. Lyman 410
Chapman v Robinson 412, 413
Cramer v. Loper 416
Coldren v. Miller « 420
Castill v. Whips 420
Collins v. Burkam 423
Clark v. Spears 429
Croft v. Dood 429, 443
Crane v. Gough 431
Craig v. Vanpelt 431
Copeland v. MercantileIns. Co 434
Conan v. the State 435
Calvin v. Wigam 436
Cross ¥. Wyod 436
Campbell v. Gates 436
LAW OF DAMAGES,
Section
Crane, admnr.,v. Alling 487, 438
Catskill Bonk v Messenger = 437
Couch v. Mils . 437
Com. Bk. v. W. Reserve Bk = 440
Chambers v. Cochran 440
Curan v Colbert 440
Comnwith v. Miller 440
Christian v. Brown 441
Coats v McKee 441
Cooper v. Wilcox 442
Comstock v. Crean 442
Clark v. McCleas 443
Cummins v. Garretson 443
Conway v. U.S. Bank 444
Craig v Craig 445
Coe v. N. J. M. BR. R. 415
Croke v Lewis 450
Coolige v. Bigham 452, 458
Conner v. Dempsey 454
Carr v. Moore 454
Clare v. Maynard 454, 460
Crabtree v. Kile 456
Case v. Hall 458
Chesterman v. Lamb 460
Cooper v. Young 462
Cooper v. Young 464
Crater v. Berger 465
Casewell v. Coare 466
Callaman v. Brown 466
Clark v. Neefnill * 466
Comstock v. Hutchin 466
Cannon v. Folsam 467, 475
Crosley v. Watkins 467, 475
Clark v. Penn 467-8, 475-6, 480
Collen v McFadden 467, 475
Carrie v. White 469
Copper Co. v. Copper Mining
30. 479, 474
Crookshanks v. Mallory +482
Cornur v. Wall 482
Clark v. Mayor N. Y. 484
Cost v. Ambergot 485
Cortegon v. Mana 485
Coe v. Smith, 486, 496
Clark v. Gilbert 486
Cunningham v. Dorsey 487, 529
Clark v Smith 488
Crookshanks vy. Mallory 489
Cannon v. Wallace 495
Chamberlain v. Scott 495
Coon v. Gruman 495
Collins v. saumgartner 499
Cass v. Boston & Lowell R R. 504
Chainbers v. Shaw 504
Cankendale v. Eaton 504
Conner v. Weston 506
Coggs v. Barnard 5(6
INDEX TO AUTHORITIES CITED.
Section
Cartitue v Leesing 509
Chamberlain v. Brockett 510
.Chamkers v. Crawford 511
Cox v O’Riley 512
C.&C. AirL. Ryv.McConl 512
Chase et al vy Washburne 512
-Clark v. Rochester Co. 5138, 514
Cin. & L. Mail Line v. Boat 514
Car v. Lancashire 514
Cooper v. Young 520, 521
Cutting v. G. R. R. 521
Cortegan v. M.H. Rail Co. 529
Candee v. West. Tel Co. 535, 546
Campv. W.U Tel. Co. 535, 536
Cole v. Goodwin iS 536
Caxon v.G W. R. Co. 547
Clark v Kay 550
Carpenter v. Lockhart 550
Cathedral v. Salmage 550, 562
Chase v. Allen 5651
Charrington v. Laing 552
Crisdee v. Bolton 560
Commonwealth v. Conely 565
Carter v. Thorn 565, 566
Carter v. Carter 565, 566
Clark v. Seaton 565
Campbell v. Chamberlain 568, 569
Collins v. Sinclair
Carpenter v. Stevenson 569, 584
Carcoran v Judsen 572
Coots v. Coots 572
Comdone v. Martin 573
Chapp v Walters 581
Callaghan v. Callaghan 583,
Cooly vy Early 585
Coolege v. Gray 587
Coggeshall v. Am. In. Co. 587
Crocker v. Jackson 588
Cornegus v. Vasses 588
Cory v Bos. F.& M Ins. Co. 589
Cross v. Wilkins 727
Carman v. Marine Ins. Co. 590
Coplen v. Phoenix Ins. Co. 690
Commonwealth v. Sermet 692, 693
Carpenter v. Ins. Co. 694
Catlin y Spring. Ins. Co. 695
Cromiev.K & L.Mu.In. Co. 697
City N Y. Fire Ins. Co. v. J.
- H. & H. P. Corlies 696
Chenowith v. Hick 711
Clapp v. Hudson 711
C. R. Davidson v. Polynix 711
C. & H.R Co. v. Pondrom 711
Creed v. Fisher 711
Clek v. Udall 712, 717
Chambers v. Callfield 713
Clouse v. Clapper 714, 716
568, 573, 574.
xili
Section
Caldwell v. New Steamb. Co. 719
Chi. & A, K. Co. v. Willson 719
Chicago R. R. v. Garra 719
Clark v. Binny 720
Coffin v. Coffin 720
(lark v. McCarty 72)
Clark y. Wilson 692
Collin vy. A. & Sch. R. Co 734
Chambers v. Clamfield 722
Chambers v. Robinson 722
Carning v. Delansy 722
Collins v. Albany 722, 723
Chicago & C. R.v. Fellmore 725
Chicago & M. W. v. Jackson 725
Connelly v. McNeil 727
D.
Doughty v. Bird 5
Dent v. Toledo &c R. 6
Dascombe v. Erie R. 8
Day v. Holloway 9
Denaghue v Heath 12
Dorsey v. Memlow 13
Del. Steamb. Co. v. Wilden 13
Denslow v. Vanhorn 13
Day v. Woodward 14
Dodd v. Holmes 18
Dannell &c v. Stewart 22
Dreye v. Ming 23
Davis v. Coff 25
Daws v. Wycoft 29, 33
Day v. James 42
Doe v Filster 42
Dibble v. Morris 42, 43, 53
Dean v. Blockwell 42, 43, 53
DeNuongh v. Heath 42
Day v. Woodward 48, 204
Dexler v. Spear 58, 230
Denslow v. Vanhorn 55
Davis v. Slogle 55
Duder v. Knowles . 55
Dodwell v. Buford 58
Dole v. Eskin 59
Daily Post v. McCarthy 60
Dolard v. Hogan 65
Disman v. Wilkes 71
Dunham y. Dunham 77
Dodd v. Noris 81, 82
Doe v. Tuford 81°
Dallas v. Sellers 84
Douherty v. Gunning 86
Dering v. State 91, 92
Davis v. Russell 92
Daniel v. Mitchell 99, 110
Duckinfield v. Whihcott 102
\Dickison v. Davis 104
xiv
Section
Durell v. Haley 106
Dingle v. Hare 112, 115
Durst v. Burton 112, 113
Derry v. Fletner 124
Douty v. Bird 129
Delegal v. Higby 136
Doe v. Davis 150
Donnell v. Jones 150
Downey v. Burch 151
Durant v. Palmer 164
Dascomb v Erie R. R. 175
Davis v. Mann 176
Delefield v. Union Ferry 176
Dean v. Clayton 181
Dixon v. Bell 181
Dally v. Warrick 188
Durham v. Musselman 191
Davis v. Garrett 193
Denny v. Fletcher 200
Daily v. DismalSwamy Canal 202
Drew v. Sixth Ave R. R. 209
Donaldson v. Miss &e R. 209,
220, 225, 227
Duckwood v Johnson 220-1, 227
Dalsonv.S E. BR. R. 222
Dalton v. 8. E. R. R. 223, 228
Dickens v. N. Y. &cR. R. 223
Dunhene v. Ohio Life Co. 223
David v.S. W R R. 227
D’Armond v. Armstrong 230
Dunn v. Hall 231
Duford v. Abadi 232
Dame v. Kedny 234
Duncan v. Daniels 236
Dixon v. Caldwell 239
Dillenback v. Jerome 239
Davis v. Oswell 245
Douglass v. Kraft 247
Dennis v. Barber 249
Dudley v. Ward 253
Dewitt v. Morris 254
Darley v. Caraway 256
Deekman v. Mayor N. O. 263
Devarainge v. Fox 263
Dingley v. Barton 263
Davis v. Charles &c R. R. 264
D. L.W. R.B v. Paine 264
Deaton v Polk 265
Dunbar v. Glenn 274
Deelim v. Deelim 274
Dutrich v. Schell 277
Danforth v. Pratt 279
Douglas v. the State, ex rel.
Wright 283
Duendorf v. Werf 285, 290
Dorman v. Ames 287, 290
Dent v. Davidson 290
LAW OF DAMAGES,
Dye v. Mann
Davis v. Gale
Dwivel v. Barnard
Delhi v. Yeamans
Dalington v. Panter
Dodd v. Burche
Dewett v. Greenfield
Downey v. Burch
Delaney v. Stoddat
Denalow v. Vanhorn
Dyden v. Knowles
Douglass v. Stephens
Dunn v. Johnson
Dustin v McAndrews
Darwin v. Potter
Davis v. Fish
Davis v. Mann
Draydon v. Knowles
Denslow v. Vanhorn
Davis v. Slagle
Daily v. Shirley
Denmick v. Lockwood
Daniels v. the State
Danaldson v. M. & M.
Dudley v Kilwell
Douglass v. Scott
Doswell v. Buchanan
Dale v. Sincly
Davis v. Lyman
Delavergen \. Morris
Dalton v. Baker
Dunica v. Sharp
Dunomars v. Miller
Davis v. Lewis
Driggs v. Dwight
Dustin v. Newcomer
Doherty v Doland
Drake v. Baker
Doupe v. Cenin
Dean v. Roseler
Denning v. Dwight
Dean v. White
Davis v. Moss
Doge v Perkins
Dering v. Leas
Dooley v. Smith
Depaw v. Humphries
Dewolf v. Johnson
Duscomb v. Barker
Day v. Levenworth
Dunn v. Clement
Dorsey v. Hadlock
Deardorf v. Forceman
Dixon v. Dixon
Dean v. Newhall
Durell v. Wendell
Section
290
297
297
297
297
300
307
308
309
312
313
314
317
317, 318
318
319
319
325
325, 327,
328, 330
326
337
346, 358
347
RR 348
350
350
350
350
353, 354
3538, 354
358
361
361
362
362
362
369, 370
370
378
381
382
382
385,
390
405
406
412, 413
412
412
420
423
429
432, 433
424
487
437, 488, 439
INDEX TO AUTHORITIES CITED.
Section
Dizing v. Baily 439
Davis v. Mitchell 440
Delaplain v. Hitchcock 440
Denson v. Gibson 440
Dixon v. Ewing 442
Dorman v Biglow 443
Driscoll v Board 443
Davis v. Payne 443
DeButts v. Bacon, et al 445
Davis S.M. Cav. McGinnis 448
Duff v. Mason 449
Diller v. Moore 451
Defrees v. Trumper 452
Dean v. Mason 452
Dickerson v. Gay 454
Durst v. Burton 454
Dengle v. Hare 454
Driggs v. Dwight 461
Davis v¢ Cin R. R. 462
Delvin v. Mayer 464, 474
Dana, v. Feidler 467, 468, 475
Davis v. Shield 467, 468, 475-
Davenport v. Wells 467, 475
Dunlope v. Higgins 474
Downer v. Black 478
Dunstan v. McAndrews 481
Dermont v. Jones - 482, 489, 495
Darnes v. Fish 482, 489, 495
Davis v. Barrington 482, 495
Danby v. Williams 485
Doter v. Brown 486
Dunn v. Johnson 487, 498-99, 529
Dickson v. Caldwell 488
Dyer v. Jones 489
Dorcher v. Continental Mills 489
Dayis v. Doe 489
Derby v. Johns 495
Doolittle v. MeCollough 496.
Dowdson v Graham 501, 502
Dart v. Love 502
Dreher v. Fitchburg 503
Doorman v. Jenks 503
Duncan v. Moggett 505
Lykers v. Allen 509
DeTollemer v. Fuller 510
Duncan v. R. R Co 510
Dean v. Vaccaro & Co 515
Denny v. N. Y. Cent R. R. 517
Dawes v. N. Y. Cent R. R. 520
Deming v. Grand Trunk R R. 521
Doyle v. Kliser 526, 528
DeRuthyv. N Y., A. & B.
Tel. Co. 531, 534, 538
Dennetter v. A. &c T. Co. 547
Daniels v. Ward 550
Duff y. Shocky 550, 559, 561
Dakins vy. Williams 551, 558, 562
xV
Section
Dunlap v. Gregor 551
Davis v. Benton 552, 557
Durst v. Swift 553
Daily v Litchfield 555
Davis v. Gillett 565
Davis v Board of Com. of
Booth. Co 566
Donnell v. Jones 567
Denny v. Humphries 568
Derry Bank v. Heath 573
Devol v McIntosh 577
Dorsey v. Gasaway. 581
Devendorf v. Dickinson 582
Dodge v. Essop 587
DeLonguemore v N. Y. Ins. 587
Delaney v. N. E. Ins, Co, 588
Debloss v. Oceanic Ins Co. 590
Dewost v. Loomer 711
Dulby v. Gunning 713
bavis v. Davis 720
Doyle v. Dixon 722
Doty v. Rigour 726
Diblin v. Murphy 727
Doby v. Regour 727
E.
Evansville &c. R R. Co v.
Heath 8
Ev &c R R. Cov. Loudermilk 8°
Ev. &c R. R Co. v. Durer 8
Ellis v. Duncan - 20
Enoble v. ‘Myers 42
E &C.R.R Co.v. Bowen 45, 46
Ellsworth v. Thompson 62
Estey v. Estey 17
Edwards v. Crock 81, 86
Eager v. Grimwood 86
Ellington v. Ellington 87
Edmonson v. Marshall 88-
Edwards v. Owen 102
Ellis v. Andrews 104
Edwards v. Edwards 120
Edwards v. Beebe 125
Ellis v. Abraham 141
Ely v. Supervisor Co 155
E. & C. BR. R. v. Heath 175
Ev. R R. v. Loudermilk 175,177
E.&C R.R. Vv. Dexter 175,
E &C.R. R. v. Hiatt 176, 183
Ernest v. H. R. R. R 183
Eckert v. Long 193
Eden v. Lexington R.R. Co 208
Ewen v. Chicago R. R. Co. 224
Evans v. Harras 233
Eq. Mut. Ins Co. v. Woodruff 694
Elere v. Evans 234
xvi
Edmonson v. Nuttal
LAW OF DAMAGES.
Section
239
Ellis v. Wise 248, 244
Ewart v. Kerr 248
E. & P. R. R. v. Holmes 264
Emener v. Badger 274
Elder v. Morris’ Q77
Ellis v. Duncan 292, 295
Evans v. Murriworth 294
Elliott v. Fletcher 297
Earl v. Dutest 207
Eddy v. Simpson 297
Eastland v. Calder 307
Ellis v. Guggenheimer 323
Espy v. Jones 328, 329
Erwin v. Greenwood 330
Eewis v. Ridge 350
Engle v. Fitch 365
Estep v. Estep 376
Erie Canal v. Brett 376
Else v- Gatward 382
Elmes v, Mann 385
Elliott v. Holbrook 438
_ English v. Brown 443
Eden v. Scott 450
Eddie v Crim 452
Edwards v. Colson 454
Ellis v. Chinnack 460
Epperley v. Bailey 482
Eddington v. Pick 482, 489, 495
. Ellis v. Hamlin 488
Eyser v. Wussgisler 489
Eldridge v. Adams 603, 504
Eastman v Amy 507
Elliott v. Armstrong 508
Evans v. Fitchburg R. Co. 514
Edmonson v. Baxter 520
Erie R. Co v. Lockwood 524
Ellis v. Am. Tel. Co. 531-2.
534, 535, 536
Emmon v. Von 550
Edwards v. Williams 557
Early v. Spooner 570
Edwards v. Bodine 572
Edwards v. Edwards 573
English v. Beard 585
Eagan v. Mut. Ins Co 699
Elsworth v. Cent Co. 711
F
Fletcher v. Labin 10
Foster v. Nichols 13
Friedenstite v. Edmonson 13
Fox v. Stevens 13
Fay v. Parker 14
Floyd v. N. Y. City 19
Feila v. Desmoines 21
Section
Fenlon v. Wilson 22
’ Fay v. Parker 30, 31, 32, 34, 37
38, 44, 57
Fry v. Bennett 44, 232
Fidley v. McKinley 55
Fisher v. Bridges 59
Fillbeck v. Foster 59
Flog v. R. R. Co 60
Fuledor v. Waick 62, 305
Foreheld v. Cal Sta. Co. 67
Floyd v. State 68
Forbes v. Parson 72
Forney \. Hallett 75
Felowing v. Colmon 84
Falkner v. Scarlet 87
‘Fuller vy. Buehrer 89
Fox v. Gant 91
Farrell v. Barnett 94, 95
Fellows v. Goodman e 95, 99
Feenzel et al. v. Miller
Fuzan v. Toulman
Foley v. Cogill 101, 433
Fenton v. Brown 102
Fisk v. Hicks 112, 115, 454
Freeman v, Smith 121
Fralton v. McGally 128
Fasyth v. Palmer 129
Fayth v. Wells 132
Fosha v Ferguson 136
Farmer y. Darling 137, 141, 145
French v. Smith 142, 143
Fisher v. Bristow 147
Fitzgibbon v. Brown 151
First Bpt. Ch. v. 8. & T. R. BR. 152
Fenton v. Wilson S. M. Co. 152
Fish v. Doge 154
Fairchilds v. Bentley 162
Fleming v. Orr 162
Farland v Marshall 165
Foley v Wyeth 165
Foster v. Holly 177
Flynn v Hatton 185
Fent v. T. R Co. 193
Fairbanks v. Kerr 193
Flynnv.8. F.&8.J.R.R. 200.
Fry v. Dubuque & 8. R. R. 202
Fulsom v. Concord 202
Frink v. Schroyer 202, 207
_ Ford v. Monroe 209, 228
Franklin v.S E.R. R 220-23, 228
Fuller v. Fenner 232, vat
Fountain v. West 236
Fisher v. Tice 236
Freeman v. Tinsley 236
Farmers’ Bank v. McKee 245
Foythe v. Wells 245, 246, 248
Frasier v. Frederick 252
INDEX TO AUTHORITIES CITED.
Section
Fay et al v. Reddick 254
Fitzhugh v. Wiman 258
Freeland v. NC R RCo 265
FA&SRRCov. Caldwell 265
Flint v. Clark 268
Ferguson v. Daniel Miller 274
Faber v. Dunty 275
Flourney v. Jeffersonville City 278
Farmer v. Turnpike Co 279
Forsyth v. Palmer 281
Fullman v. Stearns 285, 287, 290
Freese v. Cary 287
Fray v. Vouls 290
Fifty Association v. Tudor 301
Fuller v. Dean 307
Fletcher v Burrows 307
Faulke v. Selway 312
Foster v. Wells 313
Flower v. Adams 319
Frost v Knight 821
Field v. McKinley 827
Feble v Coplinger 328
Fidler v. McKinley 829
Furlong v. Polly 329
Fleming v. Beck 329
Flureau v. Thoruhill 333, 334, 362
Farmers’ Bank v. Glenn 337, 354
Foster v. Thompson 837
Furniss v. Ferguson 346
Foot v. Burnet’ 347, 3538, 354
Farland v. Williams 350
Funk v. Voneda 354
Faucet v. Wood 355
Funk v. Caswell 356
Fletcher v. Button 357
Fold v. McKingan 361
Franchot v. Leach 370
Furnical v. Crum 376
Fowler v. Bott 384
Ferguson v. Stafford 386
Freese v. Brownell 412
Forse v. Elizabeth City 416
Farwell v. Kennett — 420
Fairbanks v. Metcalfe 433
Fullerton v. Sturgess 434
Farrell v. Forrest 437
unk v. Green 437
Fitch v. Sutton 439
First, &c., Bank v. Smith 443
French v. Price 445
Fielding v. Waterhouse 445
Foggart v. Blackweller
Fraley v. Bispham 454
Frink v. Tatman 454, 475, 476, 498
Foster v. Rogers 454, 458
Fates v. McKeon 454
Ferguson ‘vy. Harris 454
450 .
xvii
Section
Fleck y. Weatherton 457
Faris vy. Comstock 457, 466
Faris v. Lewis 459
Fagin v. Beasly 460
Fisk v. Tank 461
Fasselar v. Love 464
Fleming v. Beck 464
Forsyth v Palmer 477
Frazer v. Gregg 484
Francot v. Leach 485
Fenton v. Clark 486
Farrow v. Wilson 486
Fuller v. Brown 486
Fail v. McKee 487, 499
Fox v Hadding 487
Flora v. Danby 495
Furlow v. Gillan 501
First National Bank v. Nelson 507
Foltier v. Schrader 507
Franklin v.: Neal 509
Fisher v. Kyle 510
Field v. Brockett 510
Foster v. Taylor 511
Francis v. Castleman 511
Fenner v. Buff&SLRRCo 515
Farmers’, ee, Bank v. ony
land T 517, 547
Field v. Ghicsau: &e., RR Co 518
Fox v. Hurding 529
Falvey v. N W Trans Co 536
Freeman v. Clute 540
Foley v. McKegan 550, 553, 559, 566
Fletcher v. Dychi 552, 560
Freeman v. State of Illinois 565
Fox v. Mountjoy 573 '
Frazer v. Fredericks 579°
Fitch v. Dakin 580
Ferhench v. Sewell 581
Foley v McKeegan 584
Fountain v. Draper 585
Fairbanks v Kerr 585
Foster v. Eq Ins Co 694
Ford v. Ward 711
Franz v. Hilderbrand 722
Foster v. Van Norman 727
Frank v. Hessler 732
G.
Gelent v. Buckingham 9
Griffin v. Calver 10
Grobli v. Morgan 13
Gurd v Risk 13
Gelset v. Allen 13
Gordon v Jones 14
Gould v. Christianson 14, 68
Goodnight v. Goor 17
Xviil
Section
Gray v. Goodman 17
Getty v. HR R Co 17
Greencastle v. Lazeloot 20
Greenleaf v. Freese 20
Ganel v. Morton 21
Goodlove v. Cincinnati 22
Goodspeed v. East S Bank 22
Green y. M. O. 7 Conn 22
Grable v. Margrove 42
Garland v. Whaleham 44
Goddard v. G T R Co 47, 50
Goddard v. Bailey
Gaul v. Cleming 53
Green v. Craig 54
Gregory v. Hill 60
Green v. Botsam 60
Greenmyer v. Morris 62
Gaither v. Blower 63
Gallagher v. State 68
Gardner v. Maderia 78
Grable v. Margrove 79
Garden v. Jadis 82, 311
Gillcrist v. Bale 84
Gunnell v. Wells 87
Gray v. Darland 87
Grove v. Dill 88
Griffin v. Colmer 91
Gatling v. Newell 101, 102, 103,
106, 108, 109, 451, 480
Green vy. Gordon 102
Georgia v. Higgenbottoms 103
Garret v. Headstone 108
Groves v. Spier 111
Gates v. Reynolds 116
Gibson v. Wood 120
Goodlittle v Alker 122
Garrett v. Anderson 122
Gillett v. West R R Co 125-206
Gilbert v. Kennedy 131
Galloway v. Stewart 136-149
Goggons v. Messmore 150
Gould v. Bennett 150
Goldsmith v. Picard 150
Goodrich v. Warner 151-308
Goods v. East Hadden Bank 152
Gillett v. Missouri Valley R Co 152
Grady v. Walmer 154
Graves v. Shattuck 155
Grigley vy. C. Lake W Co 158
Gillett v. West 163
GCW RBEOov. Dill 176
Griffin v. N Y Cen R R Co 189
Glassey v. Hustonville R R Co 189
Gagg v. Vetter 192
Grantrel v. Egerton 192
Gallagher v. Humphries 192
Groveatt v. Williams 192
LAW OF DAMAGES.
Section.
Gramm v. Brewer 206
Galliger v. Thompson | 206-
Grotenkemper v. Harris 223.
(cuengerrech v. Smith 224
Guy v. Gregory 234
Golderman v. Stearns 234
Goodman v. Topping 235
Gar v. Seldon 235:
Grove v. Brendenburg 235
Gates v. Meredith 237-307
Greenfield Bank v. Leavitte 239,
240, 249, 809+
2
Green v. Wilkins 44.
252, 257, 259
Gordon v. Jeny
Garrett v. Wood 256.
Giery v. Cin & WillRRCo 264
Graham v. Plate 273
Gilman v. Hunnell 274
Gregory v. Brown 277
Governor v. Raly 283
Glasscock v. Lyons 283
Gillet v. Johnson 297
Ganel v. Looney 297
Givanch v. Burbank 297
Greenleaf v. Force 297
Gorman v. Hargadon 297
Glane v. Harding 301
Gaber v. Grabel 301
Greenfield Bank v. Bennett 310
Grant v. Wiley 312
Green v. Spencer 323
Greenleaf v. McCobb 325
Grant v. Durkin 328
Gooddale v. Thurman 328
Green v. Irvin 336
Gore v. Bazire 342
Gurther v. Pugsley 346-347
Griffith v. Reynolds 346
Giles v Durgo 346-356
Gibbs v. Thayer 350
Gough v. Bell 350
Gochenaur v. Mowry 350
Gloster v. Audley 350
Greenlee v. Wilcox 350
Grant v. Tallman 353-356
Gilbert vy Minn 353
Greene v. Tallman 357
Grant v. Hodges 359
Gaff v. Hawks 361
Gerault v. Anderson 362
Goodpasture v. Porter & Court-
ne 370
‘Goodson v. Nunn 370
Glazebrook v. Woodson 871
Groves v. Burdane 376
Guased v. Turner 381
Gill v. Middleton 389
INDEX TO AUTHORITIES CITED.
!
Section
Gibson v. Wells 384
Gough v. Howard 384
_ Gwinn v. McCatmont 386
Gutacapv Wamluse 424
Greese v. Wynn 436
Gahn v. Numenz 441
Greenwalt v. Keitler 443
Gillian v. Ludington 443
Griffin v. Orman 445
Gaff v. Sims 447
Gammel v. Paramore 448
‘ Griffin vy Calver 450, 456, 461,
fy 464, 539, 540
Gray v. Cox 450
Gallagher v. Waring 454
Grose v. Henry 454
Gattering v. Newell 469
Gee v. Lancaster R R Co 474
Ganson v. Moding 480
Gordon vy. Norris 480, 481
Griswold v. Sabein 481
Graham v. Graham 484
Gillman v. Hall 489
Goodard v. Barnard 491
Glass v. Garber 497
Gunther v. Pugsby 500
Gaines v. Union Trans. & Ins.
Co. 515, 518, 526
Graves v. H. N. Y. Steamboat
Co 515
Galena R R. Co. v. Roe 520
Graham v. Davis 525
Gordon v. Buchanan 525
Grover v. Carter 550
Granalle v. Londen 550
Garner v. Saltmarsh 553
Green v. Price 560
Granelli v. Lowden 562
Grate v. Gillespie 568
Gist v. McGuire 573
Gilbert v. Wiman 577
Green v Smith 580
Griffin v Culver 581
Griffith v Griffith 583
Gaw v. Mut. Fire Ins. Co. 695
Gates v. Madison Mut. Fire
Ins. Co 695
Guard v. Risk 711
Graham v. Watson 711
Garrett v. Brazell 711
Green v. Southern Ex. Co. 712
Goldsmith v. ord Sefton 722
Griffin v. Weatherspoon 727
Gibbs v. Tunnell 732
Graham v. Waterman 733
‘
xix
Section
H.
Hadley v. Baxendale 6, 11, 195
464, 118, 539
Hamilton v. McPherson 6, 310,
316, 318, 319
Hickscher v. McLeoy 6
Hay v. Gronosble 7
Hall v. Hall 8
Harper ¥. Miller 9
Huty v. Brown 13
Hawks v. Ridgway 13
Hendrixon v. Kingsbury 18,
44, 68
Hyatt v. Adams 13, 208
Hooker v. Nutor 14
Holly v. Huggerford 17
Haswood v. Benton 21
Homer v. Hinning 21
Hawkins v. Duchess, &e. 22
Hamilton v. Cincinnati 22
Hyply v. Grace et al 22
Harris v Huntington 22
Herring v. Happock 23
Hay v. Parker 25, 29
Herchell v. Money 42
Humphries v. Johnson 42-44
Hopkins v, At. R. R. Co. -
Hoodly v. Watson
Hill v. Nev. & Op. L. R. R. Co. 45
Hopkins v. A. St, L. R. R. Co
47, 202, 203
Hagar v. Prov R Co.
Hamilton v. A. R Co. 50
Hull v Richomer 53
Hill v. Glanding 54
Hopper v. Reese 59
Hendixson v. Ringley 60
Hays v. Barrymore 65
Honer v. Elder 66
Hunt v Hoyt 67
Hoodly v. Watson 68
Holyoke v.G & J. R. R. Co. 68
Healy v. Wood 68
Hill v. Rogers 69
Hathaway v. Rice 72
Huett v. Swift 73
Holmes v. Wakefield 73
Hough v. Watson 75:
Hasler v. Crill 82, 311
Hodges v. Wendham 82
Hill v. Wilson 86, 87
Huett v. Prime 88
Herring v. State 89
Hall v. Rogers 89
Holly v. Mix 91
Hall v. Rogers 95
xx
Section
Harlin v. Spaulding 96
Hill v. Bush 100
Humphreys v. Comline 101
Hague v. Grosman 101, 102
Hess v. Young 101, 102, 106
Harney v. Young 102
Humev. Pollock 102
Holbrook v. Conner 108
Hubble v. Mesis 104
Hagee v. Grosman 106
Hillsbrook v. Burke 106
Hammon v. Shields 107
Howard v. Cadwalider 108
Hardesty v. Smith 108
Hanna v. Shields 108-109
Hadley v. Smith 108
Hunt v. Silk 108
Hogan v. Meyer 108
Hiner v. Richter 115
Hohn v. Cummings 116, 466
Hopkins.v. Lee 117
Hume v. Tupts 120
Hamer v. Welsy 120
Holden v. Shattuck 122
Hass v. Borders 124
Hammond v. Reese 128
Haskins v. Philllps 128
Hart v. Evans 129
Heard v. James 132
Hays v. Blizzard 135, 136, 147
.Hall v. Suydam 137, 140, 146
Hurd v. Shaw 149
Hicks v Dorn 158
Hartshorn v. Ink §. 159
Harvard College v. Stearn 159
Humpbreys v. Bragden 165
Hay v. Lecher 168
Hoffman v. Union Ferry Co. 170
Howe v. Young : 175
Haven v. Erie R. W. Co. 176
Haley v. Earl 176
Hance v. Cayuga R. R. Co. 176
Haycraft v. Crease 181
Hawkins v. Cooper 182
Huel Senkenkamp v. Citizens’
R. R. Co. 182
Harty v. Central Co. 183
Hughes v. Mayfie 185
Hatfield v. Roper 185, 186
Holly v. Boston Gas Light Co.
185, 186, 187
Hathaway v. Toledo, &c., R. R.
Co. cl 185
Honingsberger v. Second Ave-
nue R R. Co. 186
Horr v. Parks 186
Hughes v. Macfia 187
LAW OF DAMAGES.
'
Section
Hardcastle v. South Yorkshire
R. W. 192
Houndsell v. Smith iM
Holland v. Vance
.G. TR. R. Co. 192
Holyoke v 202, ‘203
Higgins v. Dewy 197
Hendrickson v. Kingsbury 203
Harrison v Harrison 205
Howard v. Groves 206 *
Hopkins v, Atlas R. Co. 207
Hunt v. Hoyt 207
Hanover v. Coyle 207
Hunt v. Chicago R. R. Co. 224
Huntington v. Decker 226
Hutchison v. York R. R. Co. 229
Hicks v. Foster 232
Hunt v. Jones 232
Hartcourt v. Harrison 234
Holly v. Burgess 234
Haun v. Wilson 234
Hosley-v. Brooks 234
Humphreys v. Parker 234
Harberson v. Shook 234
Hawes v. Stapord 234
Hayward v. Foster 236
Hurd v. Hubble 239, 245
Heldborn v. Brown 239
Haden v. Bartlett 239
Hyde v. Coopson 248
Harvey v. Harvey 253
Hurd v. Gallager 256
Hayden v. Anderson 258, 309
Hayward v. Mayor N Y. 263
Halderman v. P & C R.R. Co 263
Hatch v. Cincinnati lt. R.
Hunt v. Smith 263
Homestein v. A. &G. W. R. R. 264
Henry v. Dubuque R.R. Co. 265
Hall v. Wiles 269, 327
Holland v. Fox 270, 271
Hubble v. U.S. 271
Holloway v. Holloway 274
Holliday v. Baird 274
Hostler v. Vansickle 274
Holten v. Smith 274
Hays v. Porter 279
Hamilton v. Marsh 279
Hudson vy. Wilkint 279
Hammer v. Griffith 279
Hartman v. Shriner 280
Hunter v. Bacon 281
Hopple v. Higbee 281
Hill v. Loomis 281
Holmes v. Peck 282
Hoby v. Built 283
Hogan v. Riley 286, 290
INDEX TO AUTHORITIES CITED.
Section
Hutchinson v. Schimmifelt 289
‘Hope v. Ally 289
Hunt v. Donal 290
Holderman v. Burkhardt 295
Hawksworth v. Thompson 295, 297
Howard v. Ingersoll 297
Hill v. Newman 297
Humphries v. McCall 297
Haight v. Price 297
Hill v. Smith 297
Haldeman v. Buckhart 297
Haversteck v. Lipe 300
Hubbard v. Town 800, 301
Holmes v. Elliott 301
Helsteck v. Lipier 301
Hogson v. Jeffers 301
Hays v. Border 303
Hoct v. Reed 307
Henson v. Veach 307
Hawley v. Warner 309
Hecksher v. McCray 310
Hedges v. Wendham 311
Heanamlon v Kramer 317
Hunt v. Crane 317
Hassa v. Junger 319
Harrison v. Berkly 319
Hollawell v. Griffith 321
Hubbard v. Bonsti!l 323
Hoit v. Moulten 323
Hay v Graham 323
Hunt v. Peak 327
Harrison vy. Case 827
Hocker v. Blake 337
Hosford v. Wright 337
Hemuning v. Withers 337
Hoot v. Spade 346
Hiser v McCollis 349
Howell v. Richards 349
Hoyt v. Dimond 350
Harris v. Morris 350
Hamilton v. Wilson 350
Harlow v Thomas 353
Herrick v. Moore 353
Hall v. Dean 853, 354
Henderson v. !l]enderson 354
Hubbard v. Norton 355
Hopkins v. Grosback 257
Hill v. Hobart 357, 370
Hammon v. Hannier 361, 362
Hendon v. Venable 361
Hall v. Delaphaine 361
Hopkins v. Lee 370
Harding v. Wilson 375
Hart v. Windsor 376
Hexter v. Knox 377
Hinkly v. Beckwith 380
Holmes v Davis 380
xxi
Section
Hughes v. Hood 381
Hyatt v. Wood 383
Handon v. Johns 383
Harder v. Harder 386, 387
Harding v. Coning 405
Haywood v. Haywood 418
Hobert v. Kimberly 420
Hudson v. Noble 420
Hixson v. Hixson 420
Hollanback vy. Wilbard 423
Hubble v. Brown 429
Herold v. Scott 429
Harris v. Pierce 429
Hoa nd v. Hatch 435
Hunter v. Postlewaite 435
Harbert v. Dumont 435
Hall v. Thompson 436
Hubble v. Carpenter 437
Houston v. Hurly 442
Hemstead v. Watkins 443
Hamlin v. McCallister 443
Hite v. Campbell 444
Holmes v. Weed 444
Haden v. Cadat 444
Hough v. Ztna Life Ins. Co. 445
Honse v. Fort 449, 450
Hadley v. Baxendale 450, 521
Hawkins v. Berry 450-
Howard v. Foster 451
Hermance v. Venoy 452
Hubbard v. Johnson 452
Hale v Smith 452
Huntington v. Hall 452
Holden v. Daikin 452
Hall v. Plassan 452
Hargrave v. Stone 454
Houghton v. Carpenter 454
Hook v. Stowell 454
Hogan v. Thornington 463
, Hamilton v. McPherson 464,
; 474, 529
Houg v. Myers 469
Haskell v. Iiunter 469, 476
Hamilton v. Ganyard 469
Hinde v Liddle 472, 477
Hamilton v. the G.N. R Co. 474
Hale v. London & N. W. R. Co 474
Hinkley v. Beckwith 474
Harper v. Smith 475
Harrison v. Harrison 478
Haskill v. McHenry 480
Howard v. Daly 485
Hunt v Crane 485
Hale v. Belden 486
Hensen v. Hampton 488
Hubbard v. Belden 489
Hayward v Leonard 491
XXli
Section
Heaton v. Colgrove 492
Hunt v. Collins 495
Hall v. Boston & Worcester R.
R. Co. . 504
Hugh v. London R. R. Co. 504
Holbrook v. Wright 504
Hill v. Wiggins 504
Haver v. Love 507
Humaker v. Sturgis 508
Hutton v. Arnett 509
Homer v. Swing 510
Harper v. Bound 512
Huntingdon v. Drake 513
Hall v. Denfro 514
Hyde v. T. & M. N. Co. 517
Hobbs and wife v. L. &S W
R’y Co. 527
Hawkins v. Hoffman 527.
Hecksher v. McCray 529
Hubbard v. W. U. Tel. Co. 541
Hulston v. Norman 547
Hamilton v. Overton 550, 553,
: 559, 562
Huff v. Lawler 551
Hazlewuck v. Tappen 551, 562
Hogland v. Sequr 551, 559
Hosmer v. True 553
Hannaman v. Breedenbock 555
Horner v. Flintaff 557
Hise v. Foster 559, 562
Hardee v. Howard 562
Holbert ex rel v. Commissioners
of Martin County 565
Hancock v. Hazzard 565
Hellen v. Ardly 566
Hughes v. Wynn 566
Hughes v. Wickliff ° 566
Harrison v. Wright 566, 584
Hosham v. Hosham 568
Hayden v. Sample 568
Harper et al v. Keys 569
Hamilton v. Steele 574
Ham v. Groves 575
Ham v. Hill 576
Hayden v. Cabott 577
Hallock v. Belcher 578
Hugerford v. Kedford 579
Hedrick v. Young 579
Hamilton v. Brewster 583
Harvey v. Royal Exch. Asso.
0. 587
Haley v. Drenchler Mutual Fire
Ins. Co. 692
Hoffman v. Ins. Co. 693
Home Ins. Co. v. Thompson 694
Hough v. People’s Ins Co. 696
Harris v. Protection Ins, Co. 696
LAW OF DAMAGES.
Section
Hutchins v. People’s Ins. Co 699
Hamilton v. Cunningham 708°
Harris v Rupel 714
Harry v. Watson ; 722
Hall 'v. Bark Onily Banning 730
Howard v. Barnard 732
Hudspeth v. Allen 732
I.
Illinois Central v. Hummer 50
L, B. & W.R. Co. v. McBowen 53
Ireland v. Ellart 64, 66
Ingersoll v. Jones 88
Irwin v. De Cannon 88
Ingram v. Morgan 104
Israel v. Brooks 151, 308
I. P. & C. R W Co v. Anthony 152
Indianapolis v. Miller 156, 161
Till. Cen. R. R. Co. v. Grabill 159
I. & P. R. RB. Co. v. Petty 177
I. C. R. R.Co. v. Finnegan 163, 314
I P.& C.R. R. Co. v. Rubey 175
Illinois Central v. Phelps 176
Ill. Cen. Co. v. Hutenison 177, 190
Indianapolis R. Co. v. Bowen 178
I. & St L. R. R. Co. v. Stout 178
Ill. R. R. Co. v. Craiger 178
Til. R. R. Co. v. Hall 178
I. & C. R. R. Co. vy. Caldwell 181
I. B. &W.R. R. Co. v. McBrown
181, 182
Ind. & Cin. R. R. Co. v. McCluer 182
Tl. v. 42d Street R. R. Co. 188, 223
I.B.& W. R.R. Co. v. Carr 193
Indianapolis v. Gaston 203
Til. Cen. R. R. Co. v. Baches 220
Til. Cen. R. R Co... Weldon 220
Innman v. Foster 234, 307
Ingalls v. Lord 250
Irvin v. Miss. C. R. R. 264
Irwin v Dixon 301
Irvin v. Greenwood 327
Izon v. Gaston 376
Ives v. Ives 883
Ind Ins. Co. v. Thomas 405
Inglethem v. North R. Co. 520
Insurance Co. v. Updegraff 694
Ill. Cen. R. R. Co. v. Welch 722, 723
Ill. Cen. R R. Co. v. Weldon 722
J.
Jones v. Vanpotter 6
Jefferson v. Adams 13
Johnson v. Camp 18, 61
Jennings v. Maddox 13
INDEX TO AUTHORITIES CITED.
. Section
Jones vy. Rahilla 13
Jones v. Turpin 14
Judson v. Cook 23
Jonesv Jones 438, 51, 482, 489, 495
Johnson v. Jenks 55, 310, 325
Jobnson v. Thompkins 59
Jackaway v. Dooley 62
Jones v. Thompson 84
J8hnson v. Maxon 97
Jenkins v. Lang 101,:102
Junkins v. Simpson 104
Jenks v. Long 106
Jackson v. Wilcox 106
Johnson v, Cook 107
Jenks v. Simpson 107
Johnson v. Cookerly 108, 109
Johnson v. Jones 109
Jones v. Justice 112, 115
Jeffy v. Biglow 113
Jarrett v. Genathmey 121
Jarrett v. Gatling 122
Jackson v. Hathaway 122
Jones v. Gooday 129
Johnston v. Sutton 187. 141
Jacks v. Stimpson 149
James v. Phelps 151
Jenks v. Turner 161
Jeffersonville R. R. v. Swift 175
Jobnson v. Hudson R. 176
Johnston v. Stebbins 230
Johnson v. Stear 239, 290
Jenkins v McConico 248
Jones v Rohill 249
Jenuings v. Johnson 258
Jamesv.James , 274
Jewett v. Whitney 290
James v. Williams 297
Jackson v. Halstead 297
Johnson v Jordon 297
Johnston .. Calkins 812
Jones, adm.. v. Pattent 315, 316, 317
Jackson vy. Winslow 349
Jackson v. Wright 350
Jenks v. Hopkins 358, 359
Jetter v. Glenn 358
Johnson v. Arnold 382
Jones v. Reed 384
James v. Brooks 429
Jamison v..Grovenor 439
Joseph v. Heaton 441
Johns v. Reardon 441
Jenks v. Clark 443
Johns v. Johns 444
Jackson v. Adamson 445
Juda v- Neiure 445
Jones v. Bradford 446
Jones v. Zuick 450
Xxili
Section
Jones v Bright 450, 457
Johnson v. Coke 452
Jefferson v. Biglow. 459
Jones v. Van Patten 486
Jones v. Judd 486
Jennings v. Camp 488
Jewell v. Schappell 496
Johnson v. Hudson River Co. 503
Jenkins v. Bacon 504
Jackman vy. Partridge 505
Jourdon v. Reed 506
Jourdon v. Sherman 512
Jonnson v. Midland Co. 514
Jeff. R. R. Co. v. Cleveland 515
Jackson v. Rodger 519
Jordan v. Fall River & L. E.
Railway Co. 527
Jamison v. Grey 559, 562
Jones v. Doneberger 575
Johnson v. Shelden 592
Jones v. Sparrow 722
K.
Kepka v. Sargeant 11
Ky. R. R. Co. v. Dells 13
King v. Root 14
Kendal v. Stone . 14
Keanas v. Schuylkill 22
Judson v. Cook 22
Kloffer v Romane 44
Kiffin v. McConnell 55
Krone v. Schoonmaker 56
Keslard v. State 59
Kilper v. Hyer 60
Key v. Dembin 61, 66, 67
Knight v. Wilcox 86, 87
Kendrick v. McCray : 87
Koener v. Oberly 96
Kingley v. Wallis 106
Kilroy v. Ross 106
Kimble v. Cunningham 108
Kreesan v. Cloud 110
Knowles v. Nunn 118, 459
Kirkpatrick v Kirkpatrick 137, 149
Kidred v. Stilt 150
Kearney v. Farrell 153
Kerwhacker v. Cleveland R. Co 177
Kerwhacker v. C. C. & C. N. R.
R. Co. 180
Kearnes v. Snowden 183
Keefe v. Chicago R. R. Co, 184
Kreig v. Wells 185
Kerr v. Forgue 188, 202
Kellogg v. C. & N. W. R.R. Co.
197, 201
Kimmel. v. Stone 205
XxXiv
Section
Keller v. N. Y. R. R. Co. 223
Karney v. Paisly 224
Kansas & Pacific R. R. v. Cutter 226
Kennedy v. Whitemill 239
Kennedy v. Strong 239
King v. Oesir 239
Kerr v. Patterson
246, 248, 313
Kohl v. U.S. 262
Keenas v. Schuylkill Bank 269
Kimble v. Kimble 290.
Kaler v. Beamore 294
Kelly v. Notono Water Co. 297
Kemble v. Gilbert 297
Kidd v. Laird 297
Kauffman v. Gisner 297
Keato v. Hugo 300
King v. Miller 301
Klofer v. Brown 312
King v. King 328, 324, 328
Krufford v. McConnell 826, 329
Kelly v. Renfro 327, 328
Kelly v. Riley 329
Kansas Pacific R W. Co. v. Don-
myer 336
King v. Norton 336
King v. Gibson 337
Keeler v. Wood 342, 349, 358
King v. Kersey | 846
Kimball v. Blaisdell 350
Kennedy v. McCarthy 350
Kerr v Shaw 350
Kingdom v. Nottle 351
King v. Jones 351
Kent vy. Cantrell 354
Kellogg v. Sweeny 405, 407
Kilgore v. Dempsy 412, 413
Kirkland v. Moulton 420
Kelsey v. Ross 429
Kuntz v" Hart 435
Kearsly v. Cole 436
Klingensmith v. Klingensmith 439
Knight v. Whitehead 441
Kaufman v. Wilson 443
Kelly v. Matthews 443
Kimball! v. Cummings 444
Kenly v. Fitzpatrick 450
Krone v. Lang 464, 474
Kent v. Ginter 468, 475, 476, 479
Kountz v. Kirkpatrick 469, 475,
477, 480
Kelly v. Bradford 496
Knowing v Manley 504
Kemp v. Falow 506
Klauber v. Am. Ex. Co. 513
Kent v. Hudson R R. Co. 521
King v. Woodbridge 521
Kemble v. Farren 551, 552, 553
LAW OF DAMAGES.
Section
Kury v. Jones 569
Kennedy v. Hammond 574
Kutzenger v. Reynolds 576
Kelléy v. State 585
Kroch v. Heilman 585
King v. State Mutual Ins.Co. 694
Kenston v. Merrimac Ins. Co. 696
Karasich v. Hasbrook 746
L.
Locker v. Damon 6, 310, 319
Loften v, Voles ; 8
Lafayette R. R v. Sims 8
Lindsy v. Bushnell 13
Little v. Lingle 13
Leavenworth R. R. Co. v. Rice 13
Lift v. Centur 14
Lipe v. Esenlord 14
Lashly v Hollerock 18
Lyman v. WhiteR. R.R. Co. 22
Lancing v. Mont 22
L.C & Lex. R. Co. v. Dunn 47
Lane v. Wilcox ° 1, 52
Louisville R. Co. v. Smith A383
Logon v. Austin 59
Lee v. Wosley 62
Loger v. Conn 65
Little v. Johnson 66
Lowden v. Lowden 77
Larr v. Hicks 81, 82
Lipe v. Esenlord 88
Louchheim v. Gill 100
Long v. Woodman 104
Lowe v. Oldham 106
Law v. Oldham 108, 111
Lorder v Kikule 112, 115
Lickers v. Bair 115
Lallam v. Todd 116
Lunt v. Brown 120
Lewis v. Carsom 120
Lawrence v.G. N. W. R. R. Co. 127
Luken v. Godrell 128
Lacy v. Mitchell 135, 1386
Lawrence v. Laming 135, 136
Leener v. Hamill 148
Lyon v. Handcock 150
Long v. Rodgers 150, 152
Lauerone v. Mangiante 161, 162
Lafayette R. R. Co. v.Shriner 161
Lasala v. Holbrook 165
Lofton v. Vogles 175
Lafayette R. R. Co. v. Bruner 175
Louisville R R Co. v. Collins 177
Lafayette & Indianapotis R. R
Co. v. Adams
Litchfield Coal Co. v. Taylor
177
178
*”
INDEX TO AUTHORITIES CITED.
Section
L &LR.R Co.v. Adams 182
L. & I.R. R. Co.v. Huflman 182
_Lynch v Nurdin 182, 185, 188
Leddy v. St Louis Co. 184
‘Lafayette R. R. Co. v. Huffman 185
Leham v. Brooklyn 185, 220
‘Lanner v. Albany Gas Co. 186
Lynch v. Smith 186. 187. 188
Lynch v. Knight 233
L’ & I. R R. Co. v. Huffman 189
Lent v. T., P.& W. R. R. 197
Leeds v. Amherst 201
Lindsy v. Town of Danville 202
Lindsay v. Bushnell 203
Lincoln v. 8. 8. R. R. Co. 203
‘Landon v. Humphreys 206
Long v. Morrison 206, 207, 220
Lee v. Spears 207
Lewis v. Chapman 234
Leonard v. Al’en 235
Tamonda v. Daval 239
Lingle v Schneider 258
Louisville & Nashville R. R. v.
Glazebrook 263
Litt'e Miami R R v, Collett 264
‘Lion v. Archer 289
Little v. Stanback 289, 290-
Ledbetter v. Morris 289, 290
Linder v Lake 290
Leffingwell v. Elliott 290
Luther v. the Wennet Corp. 296
Lewis v. Smith 297
Laldell v. Simpson 297
Lewis v. Baldwin 297
*Lukey v Blosser 323
Lawrence v. Cook 325
Leeds v. Cook 327
Lindly v. Dempsy 329
Lents v. Choton 329
Loey v. Marnan 337
Leland v. Stone 337
Laws v. Fury 338
Lockwood v. Sturdebaut 348
Lawless v. Collier 349
Lawry v. Williams 350
Logan v. Steele 350 .
Logan v. Moore 350-3
Leffingwell v. Elliott 353
Lloyd v. Quinley 357
Loomis v. Wadham 361
Legget.v. M. Life Ins. Co. 362, 363
Lawrence v. Chase 870
Laird v. Pine 370
Lock v. Fiezer 376
Lay v. Hewett 384
Lewis v. Jnes 384
Lines v. Mack 392, 296
e XXV
Section
Lane v. Gulckauf 405
Lake v. Eddy 411
Lee v. Pile 429
Leaf v. Gibbs 434
Lahey v. Gaston 434
Lord Harberton v. Bennett 441
Long v. Fisher 450
Long v. Hicks 451
Lacy v. Strangham 454, 455
Lukes vy. Barr 454
Long v. Langridge 461
Lawrence v. Wardwell 461
Lewis v. Rountree 464
Lorder v. Allen 469
Lamb v. Brolaski 482, 489, 495
Lingdale v. Livingston 496
Lichtenhen v. Boston & R. Co 504
Lamply v. Scott 506
Lewis v. Graham 509
Lewis v. McAfee 510
Logan v Matthias 510
Leonard v. Dunton 512
Laird v. Eichold 513
Louisville, Cin. & Lex. R. R.
‘Co. v. Hedges
Lemon v Western R. R. Co.
Lee v. Lancaster & Yorkshire
_R. R. Co. 522
Long v Mobile R. R. Co. 524
Leonard vy N. Y.. &c., Tel. Co
- 531, 534, 588, 539, 540
Lane v. Montreal Tel. Co. 540
Lardsberger v. Magnet Tel. Co.
514
515
541, 546
Legget v. Mut. Life Ins. Co. of
N.Y. 551
Leay v. Lafflin 551
Lorne v. Press 553
Lindsay v. Ainsly 553
Lord +. Gladdis 59
Lowe v. Peers 560
Long v. Werk 562
Langworthy v. McKelvey 578
Lavitt v. Dobsey 573
Loosemore v. Radford 577
Levering v. Lomme 578
Ledgator v. Charme! 583
Lightv. Mather — 587
Lindsy v. Jamison 587
Levi v. Jamison 590
Lamar Ins. Co. v. McGlashen 592
Lewis v. Buckner 592
Lucinda v. Crawford 690
Luce.v. Dorchester M. Ins. Co. 698
Lindly v. Downing 707.
Love v Hess 707
Littlefield v. City of Norwick 711
xXxvi °¢ LAW OF DAMAGES.
Section Sectiom
M. Mooney v. Miller 103
Welanahan v. Universal Ins Co 106
McKnight v. Ratcliff 5 ‘atlock v Todd 107 -
Murch v. Concord R. Co.: ‘ Mason v. Barrett 108.
Moore v. Central R Co. Millikin v. Latchem .108:
Masterton v. Mayor of Brooklyn 16 Mason v. Bonet 108.
Mitchell v. Billingsby 12 | McFerran v. Taylor 110, 111
McNamee v. King 18, 42 | McCormick v. Malin 111
Millson v. Hock 13 | Moore v. Hutchinson if
Maryland, Baltimore, &c., R. R. Miller v. Eno 112, 115-
Co. v. Blacker 13 | Merny v. Jennings 112
McKeon vs. City R. R. Co. 13, 16 McAna v. Wright 112
Manly v. Dunbar Morris v. Hutchison 1138, 115.
Marsher v. Allen i | Mullett v. Mason 113
Mahan v. Brown 17,18 | Mably v. Alexander 116
Moyer v. Lord 21 | McFarlang. Smith 120:
McCray v. Guardian Poor 22 | Miss & Tenn R. Cov. Deaneny 123
McCall v. Price 23 | McLaughlin v. Bangor 125-
McKeen v. McLaughlin 27 | Mitchell v. Bellezeber 125
Mencher vy. Harvey 41,42 | Moody v. Whitney 128, 313.
Meyer v. Bohlfing 41,42 | Morton v. Porter 128
Mercer y. Butler 42 | Muller v. St. Louis R. Co. 129
McCarthy v. Niskin 43,51 | McKnight v. Roctriff 129
MemphisR.R.Co.v, Dunlap 48 McHenry v. Marr 131
Mendelsohn v. Anchor L. Co. 45 | McGuin’v. Grant 131
McManus v. Crechet 46 | Martin v. Porter 132
M. & C. R. Co. v. Whitfield 47 | Martin v. Powell 132
Mil. & St. Paul R. R. Co. v. Armo May v. Tappan 132
47, 56 Mitchell v. Jenkins 137, 138, 145,
Marford v. Woodsworth 50 146, 148
Memphis Co. v. Greén 51 | Munns v. Dapant 141
McAnoy et al v. Wright 52 | Mitchell v. Williams 145
Mulison v. Hirsch 52 | McLain v. Bank 146
Moody v. Leverich 56 | McKowen v. Hunter 150
Matthew v. Olerton 59 | McLane v. Birdson 150°
Matthew v. Long 62,72 | Martin v. Hardesty 151, 308
Morris v. Platt 66,68 | McKeon v. Lee 154
Mose v. A. & Y. R. Co, 67 | Miller v. Burch 155
McGue v. Stone 68'| McCowan v. Whiteside 158, 159
Morris v. Cornell 71 | May v. Burdette 162
Moore v. Z, &., R. R. Co. 73 | Murray v Lovejoy 171
Mason v. Canfield 89 | Munch v. the Concord 175
Monroe v. Merrill 93 | Moore v. Central R. R. 175
Modisett v. Johnson 93 | Michigan S. & N. Ind. R.R
Moore v. Crose 96" Co. v. Lantz 175
Marsh v. Smith 96 | Morris v. Phelps “176
McCall v. McDowell 96 | Mengees v. Harlam R. R. Co. 176
Mortimer v. Thomas 96 | Morrissy v. Wigging Ferry Co. 177
McLane v. Cook 97 | Macon & Co. v. Davis 177
Monroe v. Prichett 98, 99, 110, 111 | Miss. R. R. Co. v. Mason 178
McConner v. Malin 99 | Manly v. Wilmington 178
McFerra v. Taylor 100 | Mayor of Colchester v. Brooks 180
Morgan v. Snapp 101 | Moore v. Morgue ee
Mulberry v. Watson ~ 101 | Morgan v Atherton 185
McClellan v. Scott 101 Magam v. Atherton Ex. 486, 187,
Manning v, Allen 103 200
Medly v. Watson 103 | McMahon v. N.Y. 187
ANDEX TO AUTHORITIES CITED.
Section
Mangan v. Brooklvn R Co 188
McMillan v. Burlington Co. 188
Meyer v. Pacific R. R. 190
Milwaukee, &c., R. R. v. Kel
, logg 200, 202
Monted v. Mallison 200
Memphis, &c., R. R. Cov. Whit-
field 202
Moody v. Osgood 203
Morse v. Auburn R R.Co. —.208
Morris v Chicago, &c. R. k. 203
Milwaukee & St. Paul R. R. Co.
v. Arms 204
McCandless v. McWha 207
McIntyre v. N. Y Cen. R. Co.
220, 221, 223, 225
Matthews v. Warner 226 227
McGee v. Sodusky 234
Miles v. Vanhorn 234
McNutt v. Young 235
McCabe v. Blanter 235
McCabe v. Platter 235
Miles v. Harrington 236.
Moore v. Clay 236
McClintock v. Crick 236
Mosler v. Harding 236
Maitland v. Goldrey 236
McCommock v. Penn. Cen. R.
R. Co. 239
McDonald v. North 240, 245
Moody v. Whitney 246, 248
Menkins v. Menkins 250
Mitchell v. Burch 252, 256, 257, 259
Morgan v. Reynolds 256
McGarrock v. Chamberlain ong
Mayberry v. Cliff 256
McNally v. Shobe * 256
Mootle v. Chicago, &c , R. Co. 256
McCormick v. Town of "Lafayette
262, 263
Meacham v Fitzburg R. R. Co. 264
Montgomery Gravel Road Co. v.
Stockton 264
Minn Cen R RCo v McNamara 265
Marsh v. Billings 273
McClane v. Fleming 278, 274
Meneely v. Meneely 274
Morgan v. Schmackhofer 274
Menlue v. Menlue 274
Miller v. Sears 276
Maston v. Holsey 276
Morgan v. Dudley 277
Morgan v. Hughes 277
Mullett v. Chollis 279
Marshall v. Simpson 279
Mills v. Gilbert 280
McMichael v. Mason 281
XXvii
‘ Section
McNeanly v. Jewett 286
Measely v. Hunter 286
Marzette v. Williams 287, 288, 290
Monroe v. Stickey ? 288
Monroe v. Gates 288
McConnell v. Kibbie 289
McElroy v. Globe 290, 297
McCarty v. Beech 290
Murry v Bishop 290
McLain v. Black 290
Morris v. Beckwell 297
Morgan v Mason 297
Mayor v. Commissioners 297
McCord v. High 297
Mandeville v. Comstock 297
McKinney v. Smith 297
Mitchell v. Parke 297
Miller v. Louback 298
Mark v Gault. 298
Muller v. Stricker 800, 301
Maynard v. Esher 300
Myers v. Grimmel 300, 301
Morrison v. Magarth 301
Marker v. Milligan 306
Mullet v. Hulton 807
Matson v. Buck 307
McAlexander v. Harris 307
Morris v. Baker 307
Moyer vy. Pine 307
Morris v. Summerville 309
Miller v. Mariners’ Church 310,
316, 319
Miller v. Stone 312
McGee v. Stone 319
Murvin v. Hastings 323
Moore v.’Graves 323
Miller v. Hays 330
Morgan v. Yasborough 330)
Marshall v. Fiske 335.
Marston v. Hobbs 337, 850:
Martin v. Long 337
Morris v. Phelps 346, 349
Michaels v. Mills 346
McAlpin v. Woodruff 346:
iller v. Catlin 348.
McGay v. Hastings . 349, 357
Martin v. Baker 349, 351, 352:
Mark v. Willard 852:
Masse v. Sebastian 350
Mason v. Manchester 350
Mitchell v. Warren 350
‘Maule v. Schu 351
Mason v. Cooksy 353
McGary v. Hastings 354
Mitchell v. Stanley 355
McClelland v. Moore 355
McDonald v. Dunlap 357
XXVili
Section
Manahan v. Smith 357, 448
Mills v. Catlin 359
McConnell Heirs v. Dunlap 362
Martin v. Wright 362
Margraf v. Muir 364
Mack vy. Patchin 365, 376, 377
Morgan v. Wood 370
Marshall v. Harney 370
Morris v. Saunt 374
Mayor v. Moline 376
Moffatt v. Smith 376
Myers v Burns 377
Moore v. Weber 378
Morrill v Mackman 378
Mugford v. Richardson 383
Morrill v. De La Granza 383
Merritt v. Judd 385
McGregor v Brown 386
McCaslin et al. v. State 386
McCulloch v. Maryland 401
Mann v. Cross 410
McDonald v. Hodge 410
Mix v. Insurance Co. 412
Moore v. Riff 418
Mason v. Biddle 420
Murry v. Gibson 423
Merriman v. Maple 429
McCue v. Smith 431
Miller v. Parker 434
McCarthy v. Peppers 434
Muller v. Stewart 434
Morgan v. Smith 436, 437, 439
McClelland v. Cumberland Bk 487
McAllister v. Sprague 437, 439
Mason v. Jewett 439
May v. Pettengill 440, 442
McNutt v. Wilcox* 440
Marby v. Dixon 442
McWilliams v Mason 443
Manufacturers’ Bank v. Cole 443
Macey v. Adams 444
Maxwell v. Day é 444
Muldoon v, Whitlock 445
MeMiller v. B H. B. 447
Mann v. Everston 450
Morrill v. Wallace 450
McFalon v. Newman 450
Marsh v. Weber 450
Margerton v. Wright 451
Mixer v. Coburn 452
McKinney v_ Fort 452
Moses v. Meade 452
McCleur v Jeffrey 453
Magee v. Lingsly 453
Mante v. Gross 454
Merriman v. Chapter 454
Muller v. Eno 454, 458
LAW OF DAMAGES,
Section
Moulton v. Parker | 454
Merrimac Manufacturing Co. v.
Zuinter 454, 474
Moulton v. Santon 454 .
McGarve v. Wood 454
McAlpin v. Lee 454, 466
Marsh v. Weber 459
Mullett v. Mason 460
McAfee v Crawford 461
Morgan v Ryesan 466
McKnight v. Dunlap 467, 475
Muller v. Marine Church 468
Millison v. Hoch 469
Messmore vy. N. Y. Shot and
Lead Co. 475, 477
Northrup v. Cook 476
Montgomery v. Reese 477, 479
McCormickv.N. Y. & E. R Co 481
McKenny v Springer 482, 489, 495
McClure v. Secrist 482
McCoy v. Hedges 482
Mitchell v. Wiscotta 482, 489, 495
McAice v. Hale 482, 489, 495
McKing v Springer 482, 495
McClelland y. Snider 484, 498,
498
Milnes v. Van Horn 486
Masterdon v. Mayor 487, 496,
498
Morrison v. Lovejoy 488, 496.
McMillan v. Vanderbig 488
Morris v. Cummings 459
McCoy v. Hedges 489, 405
Meash v. Richards 491
Mend v.-Ithaca & Oswego RR 491
Mayor v. McLester 402
McIntosh v. Sherman 495
Mosford v. Ambros 496
McNabb vy. Lockhart 506
McLane v. Rutherford 506
Martin v. Culberson 506, 507
Markham v. Joudin 508
Mayor of Col. ». Howard 510
McNeills v. Brooks 510
McCain v. Kimbell 611
Mich. South & N. E. Ind. R.
R Co. v. McDonouogh 514
McManus v. Yorkshire dl4
Myers v. Linche 514
Marshall v. Am. Exp. Co. 519
Moses v. Boston & Maine RR 515
Morris & Essex R Rv. Ayers 515
Mobile & G. R Cov. Prewitt 515
McMaster v. Penn. R RCo 515
Man. Oil Co v. Cander & R
R Co 517
M.D. T Co. v. Balles 518, 526
i INDEX TO AUTHORITIES CITED. xxix
Section Section
Mich.8.&N.I. R.v Carter 520] Neghengale v. Scaumon 13
McGregor v. Killgan , 520 | N.C., Greenville RR v. Parton 14
Meding v. N. Y. &c. R. R 520 | New York v. Merriman 14-52
Mecram v. G. West R. R. 527 | N. &S. R. Co. v. Peterson 20
Morow v. a 527 | Newell v. Brocknell 21
Morrison v. Lovejo 529 | Nassonnon v. Rickets 42-44
McAndrews v. E Pel. Co. 531, 585 | N O. R. Co v Statdon 54
Manuel v.W. U. Tel. Co. 535 | Nixon v. Brown 76
Miller v. The Mar. Ch. 540 | Norfolk ¢. Germania 78
Murschampt v. Lancaster etc. Norfolk v. Bedding i: 78
R.R 547 | Norton v. Warner 85, 311
Mitton v. the Mid R. R. 547 | Naegley v. Linds 107
Mason v. Calender 550 | Neblett v. Merarlavd 109
Mages v Lowell 550 | Newsam v. Carr 145-151
Mead v. Wheeler, 551,’5. ’62 | Newell v. Downs 145, 150, 152
Maurice v. Body 553 | Noell v. Rook 150
Muzzy vy. Shattuck 565 | Norris v..Baker 154
Mockworth v. Thomas 565 | N H.S.Co. v Vanderbilt 163
McCoy v. Elder 565, 575 | Nicholson v. Erie RR. Co. 183
Morton v Taylor 566 | North P. A R. v. Mahoney 188
Means v. Price 568 | Nones v. Northouse 202
Myers v. Farrall 568 | North Pa. Co. v. Robinson 220-229
McCollough v. Watson 569 | N. Y. Co. v. Silbeck 239
Miller v. Goodman 571 | Nuber v. Kelley 249
Miller v. Hays 571 | N. Y. E. Co. v. Flynn 254-256
McCrea v. Brown 573 | Noble v. Eppelly 258
Miner v. Bullard 573 | New OrleansG. W. R. R. v.
Morgan v. Negley 574 Lagorda 264
Monthon v. Richardson 574 | N.J.&G.NRR.v. Mayo 264
Moore v. Crochet 580 | Nam v. Baird 282
Mosely v. Baker 580 | Nelson v. Russ 282
McGanock v. Chamberlain 581 | Nooman v. Illsby 288-290
Maxwell v. Egan 583 | Nosatti v Page 290
Martin v. Del. Ins Co 588 | Norton v. Valentine 295
' Montagu v. London Ins. Co. 589 | Notoma etc. Co. v. McCoy 197
Matheson v. Eq. Mar. Ins. Co. Nevada Water Co. v. Powell 297
590, 291 | Newbol v. Iverson 297
Maryland Fire Ins Co v. White- Nepier v. Birlwinkle 3800
ford 695 | Nelson v. Evans 307
Mich Fire Ins Co v. Nichols 696 | Night v. Foster 307
Merick v. Ger. Fire Ins Co 696 | Noice v. Brown 321
Mayor of N.Y. v. Lord 696 | Nosler v. Hunt 337, 349, 359
McDonald v. Fithian 707 | Nichols v. Walters, 337, 359
Meyerman v. Davis 707 | Nutting v. Herbert . 337
Markle v. Steele 707 | Norton v. Babcock 355
Maning v. Gashtrie 710 | Newton v. Harland 383
Marshall v. Gunter 711 | Naylor v. Moudy 433
Macon v. Winn 712, 717 | Newcomb v. Gahn 441
McConnal v. Hampton 722 | Nichols v. McDowell 443
Moore v. Martin 722, 723 | Norton et al vy. Hooten et al 452
Mortimer v. Thomas 722 | Northrupt v. Cook . 469-480
Murry v Hudson 723 | Nebo v. Brown 482-495
Mobile & Mont. R. Co. v. Ash- Newman v McGregor 482, 489, ae
craft 724 | Nelson v. Pleppston 485
Murry v. Hud. R. R. Co. 725 | Nearn v. Harbert 485
McDonald v. Waters 730 | Niles v. Brahn 489
Mariana v. Dougherty 730 | Newman v. McGregor 496
XXX
Section
Nelson v. King 505
Nevan v. Rupe 507
Nurgus v. Simpson 510
Nvnoles v. Howe 513
Norway Pl. M. Co. v. Boston
Mfg. Co. 515-517
Newell v. Smitn 524
.N. Y. C. RR. v. Fraloff 527
N.Y. & Wash. Tel. Co. v.
Daybury 526-547
Nutting v Conn. Riv. R. R. 547
Noyes v. Phillips 551
Niblo v. N. Ins. Co. 694
N.Y. Fire Ins. Co. v. Delamin 694
Newton v. Price 711
N.W. RR. Co. v. Vannatta 711
N.J. R. RK. Co. v. West 718
Neal v. Lewis 720
O.
Owen v. Hud. RR. 8, 175
Oggs v. Cy of Lacing 20
Ober v. Chapman 52
Onery v. Harden 53
O’Leary v. Roman 69
Olerine v. Baltimore RR. 73
Osborne v. Dodd 108
Oleson v. Brown 125
Ottawa Gaslight Co.v. Graham 127
Ohio & C. C RR. v. Gullet 177
O. R. W. Co. v. Shelby 177-179
O. & M. RR. Co. v. Dixon 178
O. RR. Co. v. State 181
Omarer v. Hudson RR. 188
Oflarherty v. Union RR. 188
O’ Hagan v. Dillon
Oakland RR. v. Field 207
Obio etc. RR. v. Lindell 219
O. & M. RR v. Tindal 220-228
Oldfield v. Harlem 222
Oldfield v. N. Y. ete. 223
Ohio v. Jones 281
O’Barr v. Alex. 282
Owen v. Riley 288-290
Opir Co. v. Carpenter 297
Ogden v. Marshall 305
Omstead v. Burk 329
Oweshirer v. McCallister 337-359
Old Colony R. v. Evans
370, 371, 481
‘ Owsby v. Greenwood 390
Overturf v. Martin 443
Odine v. Greenleaf 445
Osgood v. Lewis 449
O’Neal v. Bacon 450
Oneida Mfg. Co. v. Lawrence 453
LAW OF DAMAGES.
Section
Overberg adm. ve Light 454, 455
Oliver v. Hanly 457
Ocum v. Routh 479
Oakly v. the State ve
Ogden v. Marshall
Ohio & M. KR, v. Yoke etal 525
Oldham v. Kerchner ' 551
Orrv. Churehill 555
O’ Keefe v. Armstrong 582
Oldfield v. N. Y. & H. RR. 711
Ps
Parker v. Musi 12
Peoria Bridge Ass’n v. Loomis 13
Plumer v. Harbert 13
Peke v. Dellings 13
Perkins v. Somelee 14
Picket v. Cook 14, 53
Phila. RR. v. Quigley 14, 42, 42,52
Parker v. Boston x M. RR. 21
Peters v. Davis 23
Phillips.v. Rousall 23.
Pike v. Dilling 42
Parks v Costen 42
Pittsburgh & Ft. W. 47
Platt v. Brown 52
Peoria B. Ass’n v. Loomis 53-67
Parrell v. Warren 54
Pickets v. Cook 55
Phillips v. Kelly 62-66.
People v. Shorter ~ 65
Parrett v. Wells F. & Co. 71
Peters v. Lake 80
Pratt v. Fairclough _ 81
Palmer v. Cook 82-84
Phelps v. Holey 87
Phelen Kenderdison 88
Power v. Buckner 91
Perry v. Johnson 94
Parsons v Harper 94-95
Poulk v. Slocum 95
Prichard v. Parry 95
Pearson v. Morgan 99-110
Platt v. Scott 100
Post v. Williams 101
President ete. v. Connersville 101
Powell v. Bradle 105
Prentiss v. Russ 106
Potter v. Smith 107-110
Peters v. Gooch 107
Page v. Parke 111-112-114
Parson v. Dickson 120
Putnam v. Wiley 120
Perley v. Chandler 122
Potter v. Long 127
Perkins v. Hockleman 129
INDEX TO AUTHORITIES CITED.
Section
Parton Coal Co. v. Cox etal 182
Price v. Thompson 134-146
Parke v. Farly 150
Parke v. Hunt ° 150
Penoyer v Sangumad 158-159
Pettis v. Johnson et al 158-161
Pillsbury v Moore 159
Powers v City Council Bluffs 159
Page v. Hollingsworth 161
Putuam v. Payne 163
Banton v. Holland "165
Pennsylvania v. Hedson 176
Pennsylvania Co. v. St. Clair
177, 178, 179, 181
Pittsburgh Ft. W, & C. RR. v.
Vining 185-186
.P. A. Co. v. Kelly 188
P. R. Co. v. Spearen 188
Penn. RR. Co v. Kerr 194-197
Penn. RR. v. Hope 197
Perly v. Eastern RR. Co: 197-200
Peoria Bridge Ass’n v. Loomis
~ 202, 203, 207
Perkins v. Concord RR. Co. 203
Phillips v. L &S. W. Co. 204
Patton v. Wiggin 206
Penn. RR. Co. v. Keller
220, 221, 223
Penn. RR. Co. v. McClaskey 220
Penn. RR. Co. v. Zebe
220, 224, 227
Penn. RR. Co. v. Vandever 220
Palmer v. Erie RR. 221
Paulmin v. Erie RR. 223
Peter v. Chicago RR. 224-227
Peck v. May 227
Peck v. RR. Co. 228
Penn ete. Co v. Ogier 229
Petrie v. Rose . 234
Polk v. Allen 239
Parks v Boston 239.
Pierce v Berry 239
Pribble v. Kent 249, 512
Potter v, Merch Bank 250
Phoenix v. Clark 257
Pierce v. VanDyke 258
Pacific RR. Co. v. Crystal 265
Preston v. Dubuque 265
Parker v. Corbin 269
Pratt v. Gardner 276-277
Pease v. Clayton 278
Perkins v. Pittman 279
Pugh v. McRae 279
Pitt v. Golden 283
Paul v. Sloson 285, 287, 289
Pendar v. Wadsworth 290
Pollar v. Porter 290
Prescott v. Truman
Perkins v. Dorn
Parke v. Killham
Polly v McCall
Porter v. Burden
Plumleigh v. Dawson
Pettibone v Whitlock
Parker v. Edgerton
Palmer v Wetmore
Pierre v. Fernal
Powell v. Smith
Proctor v. Haggson
Parke v. Foote
Prentiss v. Shaw
Palmer v. Cook
Palmer v. Andrews
Polk v. Daly
Potter v. Deboore
Perkins v. Henry
Prescott v. Guzler
Perry v. Breakman
Paul v. Frazer
Patterson v. Win
Phillips v. Rich
Phipps v. Taplap
Perkins v. Leavitt
Xxxi
Section
290
294-297
297
297
297
297
297
298, 300
300
300, 301
301
301
301
306
311
312
316, 317, 318
323
328-325
323
328
329
335
327-346
837
. 887
Patterson v Stewart 348, 353, 356
Parker v. Brown
Pike v. Galvin
Porter v. Welsh
Pitcher v. Livingstone
Prescott v. Truman
Pomeroy v. Burnett
Peter v McKeon
Pumpelly v. Phelps
Plumer vy. Higdon
Paper v. Fravin
Paradian v. Jaine
Philip v. Stevens
Pornley v. Walker
Phelps v. Speyers
Pratt v. Stearns
Pierce v. Rowe
Peck v. Mayo
Pierce v. Hull
Perry v. Gleason
‘Perry v. Smith
Parks v. Marshall
Pierce v. Spade
Pamle v. Gunn
Peppers v. State
Palmer v. Rich
Prout v. Branch Bank
Price v. Barker
Parmalee v. Turrace
Pierce v. Sweet
349
350
350
352, 353
383
353
361-363
362-870
364-370°
370
384
384
384
405
405
405
412, 413
315
418
418
420
420
431
432-4
433
436
436
437
438°
Perrin v. Fire Ins. Co. Mobile 442
Xxxii
Section
Payne v. Webster 443
Prescott v. Brinsley 444
Powell v. Smith 444
Pratt v. Prockett 448
Passinger v. Thornburn 450
Perry v. Andrews 460
Palmer v. Pierce 461
Pittsburgh Coal Co. v. Foster
464-474
Pillpotts v. Evans 467-475
Phaland v. Ardens 474
P.C. &St. L. RR.» Heck 480, 481
Pexler v. Nichol; 482, 489, 494
Prichard v. Mastin 485
Pory v, Garth , 488
Pearson v. Williams 551
Peters v. Whiteman 491
Parker v. Tiffany 503, 504
Phelps v.: Boswick 505
Propst v. Roseman 507
Petty v. Overall | 508
Parker v. Brancker 508
Parker v. Mel. & St. L. RR. 515
Perkins v. Portl. Rk. Co. 520
Pendal v. Rench 520
Pect v. Chicago &N W.RR. 521
Parks v. Ata. Cai. Tel. 531, 536, 539
Prin. Tel. Co. v. Durburgh 531
Perkinsv. P.S &P. RY
Powell v. Brenoun 551
Price v. Green 560
Pierce v. Fuller 562
Plumb v. Woodmansee 568
Prader v. Grimes 573
Pierce v. Atly 574
“Powell v. Smith 577
Peele v. Merch. Ins. Bo. 588, 591
Patop Ins. Co. v. Southgate 590
Perie v. Steele 591
Parker v. Eagle Ins. Co. 694
Peoria Ins. Co. v. Lewis 696
Post v. Haup Mut Ins. Co. 699
Perry v. Providence Ins. Co. 700
Picking v. the State 704
Picquet v. McKay 711, 721
Penn. RR. Co. v. Goodman 711
Paulmire v. Erie RR. Co. 711
Pitts. RR. Co. v. Henning 711
Pattent v. Thompson 811
Pleasant v. Heard 711, 712
Pierce v.. Payne (2d
Pinckney v. Pulsife ~ 727
Phillips v. London 727
Proteus v. Hazel 731
Phillips v. Phillips 732
LAW OF DAMAGES.
Section
Q.
Quinby v. Vt. Cent. RR. 181
Quinn v. Moore ae 222, 228, 289
Rigby v. Hunt 6, 124
Runjen v. CS RCo 8, 175
Robb v. Mann il
Reeder v. Purdy 13
Reno v. Wilson i3
Roberts v. Means 14
Ryson v. McGuire 14
Rochester W. L Co v. Roch-
ester 19
Rooth v. Jureall 20
Russell v. Mayor N. Y. 21
Rydon v. Walcott 28
Roberts v. Mason 44
Roe v. Wilson 60
Ramonv.'N Y & ErieRR 67
Roberts v. Eldredge 71
Ramste’ v. Bost. & Alb. RR 73
Riggs v. Courgier 75
Roy v. Tucker 79, 311
Richardson v. Fout 87
Rea v. Sucker 88
Rohan v. Swane 92
Russell v. Hirab 93
Rench v. McGreggor 96, 97
Reed y. Devin 99
Reed v. Sidrner 100
Rose v. Hamly 108 -
Reed v. Duine 110, 111
Reggio v. Broggiotti 112
Richardson v. Dunn 118, 117
Reed v. Taylor 134, 141, 146
Richter v. Koster 135
Richy v. Davis 137
Rodgwize v. Tadwire 140, 145
Richy v. McBean * 149
Rodridz v Tadmin 151, 308
Rex v. Roswell
Russell v. the Mayor and City
of New York 158
Raswell v_ Prio Salk 158
Repka v. Sergeant 160
Rob v. M. . 160
Rex v. Huggens 161
Radcliffe v. Mayer 165
Richardson v. Vermont Cen R. 165
R. R. Co. v. Jones
Robinson v, N. Y. &E. R. R. Co176
R R. Co. v. Lockwood 177, 179
R. R Co. v. Hillmen 178
Raisin v. Mitchell 181
Rigley v. Huett 184, 193
INDEX TO AUTHORITIES CITED.
Section
Railroad Co.,v. Gladman 184,
: 187, 188
Ranch v. Lloyd 188
Robinson v. Cone 188
Rockford R. R. Co. v. Delaney
+ 188, 226, 227
Ryan v. N. Y. Cen. R. R. Co. 193
Ransom vy. N. E. R. R. Co. 203
Reynolds v Grover 206
Richey v. West 206
R.R. Co.v. Barron 220, 221, 223
Rawley v. London R. R. 235, 227
Rafferty v. Buckman 226
Rumsey v. Webb 234
Rayborn v. Pryor . 239
Ripley v. Davis 239
Robinson v. Hartridge 239
Reed v. Fairbanks 239
Romain v. Van Allen 246
Robbins v. Packard 250
Ramby v. Gibbs 252
Ricketts v. Dorrell 254
Rhoads v. Woods 258
Rexford v. Knight 263
Richmond R. R. Co v. Burbank 264
Robbins v. M¥. & H.R. R. Co. 264
Russell v. Place 269
Rodgers v. Nowell 274
Reilly v. Cavanaugh 282
Rosenbaum v. McThomas 287, 289
Rodgers v. Page 297
Read v. Barker 297
Root v. Driscoll 298
Rodgers v. Swain 801
Rochester v. Anderson 805
Root v. King 307
Rundle v. Moore 309
Richards v. Edick 317, 318
Roy v. Smith 323
Roper v. Clay 328
Reasoner v. Edmundson 336, 353
Riles, adm.,v. Frauntlerays 348
Rathburn v. Rathburn 349
Rigg v. Cook 350
Robertson v. Gaines 350
Reeder v. Craigg 350
Randell v. Mallet 353
Richardson v. Dow 353
Raridon v. Walpole 354
Rea v. Menkler - 355
Robertson v. Lemon 358
Roe v. Heath 358
Reese v. Smith 358
Rogstray v. Lucas 375
Ricketts v. Lostetter 379
Reed v. Reed . 383
Relman v. Jamison 383
XXxili
Section
Reed v. Resselaer Glass Fac’y 390
Reeves v. Stearns 405
Robbins v. Check 411
Roberts v. Williams 423
Rice v. Ontaco 424
Roberts v. Master 429
Russell v. Longstiff 434
Redman v. Deputy 435
Rawly v. Stoddard 487, 488, 439
Rapp v. Rapp 438
Rice v. Morton 440
Robinson v. Gee 3 441
Royal Canadian Bank v. Payne 441
Ryan v. Shawneetown 441
Rowan v. Sharp’s Rifle Co. 441
Reed v. Cox 443
Routon, adm., v. Lacy 448
Rice v. Simpson 443
Russell v. Ballard 444
Riddle v. Bowman 444
Richmond y. Houston 445
Randall v. Roper 450, 459
Richardson v. Johnson 451
Reid v. Barber 452
Robins v. Rice 452
Randall v. Rhoads 453
Rostly v. Thomas 453
Ransdell v. U.S.: 453
Rawly v. Woodruff 464
Renand v. Peck 454
Reggio v. Bragiotti 458
Rawland v. Shelton 458
Rose v. Wallace 459
Rhoads v. Baird 462
Roberts v. Carter 466
Rand v. White M. Riv. Co 467,475
Rouden v. Eaton 467
Roper v. Johnson 473
Randon v. Barton 476
Ricks v. Yates 482, 489, 488
Ream v. Watkins 486
Reab v. Moore 488
Rogers v. Beard 496
Rose v. Hill 503
Railway Co. v. Sullivan 504
Rozt v. McClelland 508
‘Ratch v. Hawes 510
Rapp v. Grayson 512
‘Richards v. Goddard 515
Russell Man. Co. v. N. H. St. Bt.
Co. 515
Redmond v. the Lan., N. Y. &
Phil Steamboat Co. 515
Redmond v. Liverpool & Co. 515
Rice v. Bos & Worcester R. R. 515
Richards v. Mich. South. R. R. 517
‘Rice v. Kan. Pacific R’y 518, 526
XXXIV
» Section
Riley v. Howe 519
Rice v. Ontario Steamboat Co. 520
Rodgers et al. v. West et al. 520
Rowe v. Steamer City of Dublin 521
Rute v. Mich. Cen. R. Co. 528
Reed v. Phil.,&c., R.R.Co. 528
Rittenhouse v. Ind. Tel. Line .
5381, 541, 544
Ruttenbaum v. Ind. Tel. Line 539
Ripley v. Mosby 540, 569, 584
Robinson v. Keny 550
Ricketts v. Trustee 550
Ross v. Ancell 557
Ranulaon v, Clark 560
Ruby v. Jones 560
Raner v. Webster 568
Ryan v. Anderson 573
Reeves v. Andrews 576
Railsbeck v. Greves 576
Redford v Height 576
Rugles v. Tilly 585
Rusker v. London Ins, Co. 587
Rodgers v. Hosack 588
Rice v. Sims 711
Russ v. St. Bt. War Eagle 712, 717
Rockwell v. Third Av. R. R. 719
Rundle v. Butler 720
Redshaw v. Brooks 720
Rowan v. People 727
Richards v. Sanford 730
Robinson v. Hudson R. R. Co 730
8.
Seely v. Alden 5,11
Scott v. Shepherd 6
Shannon v. Comstock 6, 310, 315,
316, 317, 318, 529
Smith v. Smith 8, 175
Suydam v. Street RR. 8, 175
Somes v. Wright 10
Shepherd v. Mel. G. L. Co. 10
Scannoble v. Kochler 11
Somner v. Wilt 14
Siden v. Hepburn 17
Shagon v. Knowles 18
Smoot v. Wetnauppa 19
Strong v. Campbell 20
Smith v. Yosman 20
Stone v. Deckmon 23
Sears y. Lyons 41, 42
Stimpson vy. Railroad etc, 41, 42
Symon v. McCormic 42
Sutton v. Mandvill 42
Smith v. Sherwood 42
Smith v. Wunderlich - 43-51
Storns v. Greer 43
LAW OF DAMAGES.
Section
Southerd v. Rexford . 55
Simpson v. Black 55
Stout v Wen 59
State v. Sperman 60
Smith v. Railroad Co. 50
Sherby v. Billings 64
Smithuck v. Ward 54
Stella v. Nellies 65
Suggs v. Anderson 66
‘Smith v. Holcombe 68
Stock v. Hersey 68
Smith v. Bieesby 68
Sharp v. Powell 68
Sheridon v. Fusleur 71
Sampson v. Smith 72
Sherwood v. Sitman 78
Stephens v. Walker 82
Sanders v. Nelson 82
Sanborn v. Nelson 84, 311
Stephens v. Belnapp 87, 88
Shortland v. Garrett 93.
Smith v. Gates 93
Stewart v. Maddox 96
Shain v. Davis 97
Shackelford v. Handly 98, 99
Shaffer v. Slade 99, 110
Smith v. Richards 100
Slebbins v. Eddy 101
Smar v. Canada 102
Safford v. Handy 102
Slaughter v. Gerson 103
Shaffer v. Steed 107, 500
Samy v King 109
Scotland v. Addie 109
Smith v. Richardson 110, 111
Stevenson v. Greenlee 111
Stiles v. White 111, 112. 115
Sherwood v. Sutton 112, 115
Sharon v. Mosher 112
Seymour vy. McCormick 112, 268
Smith v. Green 116
Sangster v. Prather 116
Searles v. Cromle 120
Stackpole v. Healy 122
Street v. Eoumier 125
Sprague v. Brown 125
Schuylkill Nav. Co. v. Farr 124
Smith v. Gonder 128
Stock B. Iron Co. v. Conn. Iron
Co 129
129, 131
130
Seeley v. Aldens
Simmons v. Brown
South B. Dock Co.v. Dunlap 132
Stockbridge Iron Co. v. Stove
Iron Works 132
Star v. Crocker 134
Stone v. Stevens 136
INDEX TO AUTHORITIES CITED.
Section
Seibert v. Price 136
Stone v. Crocker 187, 145, 146
Stokely v Harding 138
Seeger v. Pfifer 145
Stancliff v. Palmer 146
Sharp v. Pichel 146
Sayles v. Biggs 147
Stokely v. Hamridge 148
Stull v. Howard 150
Sandback v. Thomas 150
Sancleve v’ Eland 150
Sears v. Hathaway 150, 151
Saul v. Roberts 150
Sheldon v. Carpenter 150, 151
Smith v. Hyberman 151, 152, 308
State v. Berthol 153
St Helena Smelting Co. v
Tipping 155
Seeley v. Alden 160
Schredele v. Koehler 160
Scribner v. Kelly 161
Steel v Smith 162
Shelbyville L. B. R. Co. v.
Lemark 163
Smith v. Kimrich 164
Stengly v. Barnard 165
Solom v. Ventriesco 165
Smith v. Hines 171
Stedley v. London & N. W.
RR. Co. 176
Spooner v. Brookland 176 |
Smith v. Thomas 176
Stout v. Foster 176
Scott v. Dublin RR Co. 177
Stuke q. Milwaukee 177
Shearman v. Redfield 180, 201
: 202, 220, 319
Shields v. Blackburn 180
Stines v.Q. &S. KR. Co. 183
Stines v. Loudermilk 183
Steele v. Burkhardt 183
Stevens v. Oswego R. Co. 183
Sweeney v. Old Colony 184
Sells v. Brown 184
Singleton v. Eastern RR. Co. 185
Stout v. Sioux City RR. 187
Smith v. O’Connor 188
Scmidth v. Milwaukee 188
St. L. RR. v. Valerins 188
Sleeper v. Sandouen 190
Spicer v. C. & N. W. RR. 202
Shaw v. B. & W. RR. 208, 228
Segar v. Town of Barham-
stead 203
Suydam v. Jenkins 204, 241, 243,
246, 247, 250. 256, 477, 480
Smothers v. Hanks 206
%X KV
Section
Symond v. Henry 206
State v. Baker 207
Simonds v. Henry
Shearman v. Western Stage Co.
207
4 209, 228
Safford v. Drew 220
State of Md. v. B. & O. RR.
220, 221, 228
Steel v. Southwick 230
Simpson v. Robinson 231
Sanderson v. Caldwell 232
Swift v. Dickinson 232
Shipman v Burrows 234
Severn y. Hilton 234
Scott v- McKinnick 234
Samuels v. Bond 234
Sheanan v. Collins 234
Syngreaves v Myat 234
Saunders v. Jonnson
Shoult v. Muller 236
Sterling v. Garrett 239
Salsbury v. McCoom 244
Saunders v. Bouries 245
Sturges v. Keith 246
Stickney v. Allen 246, 247
Seals v. Cummings 250
Scott v. Rodgers 257
Seaman v. Luce 258
State v. Bockman 263
St. Joseph & D. RR. v. Orr 264
Schermer v. Lagorda 294
Stafford v. City of Prov. 264
St. L. & St. Joe RR. v. Rich-
ardson 265
St. L & St. Joe RR. v. Rob-
inson 265
Salter v. Burlington RR. 265
Schuylkill Nav. Co. v. Sherb. 265
Seymour & Dayton v. Morgan 267
Seymour v. McCormick 268, 269
Stimpson v. the RR. 269
Schwazel v. Hollenshade 270
Slack v. Landgraff 273
Sykes v. Sykes 274
Schueltzer v. Atkins 274
Stonebraker v. Stonebraker 274
Smith v. Took : 279
State v. Freeman 280
Sterritt v. ex. r. v. Keaster 286
Seal v. Morland 285
Southern RR. v. Kendick 286
Smith v. Whiting 287, 289
Stowell v. Lincoln 288
‘Strong v. Kearn 288
Shannon v. Burr 289
State v. Runhardt 290
Smith v. Jefts - 290
XXXV1
Section
Smelting Co. v. Tipping - 290
Smith v. Shockera 290
Smith v. Heuzar 290
Stowell v. Bennett 290
Selfridge v. Lithgow 290
Saunders v Stuart 290
Springfield v, Harris 292
Summers v. Brown 297
S. P. Hoffman v. Stone 297
State v. Glear 297
Smith v. Miller 297
Smith v. Adams 297
Salters v. Howard 802, 303
Spencer v. Halstead 310
Smith v. Wilburn 311
Sinner v. Dayton 815, 316
Stover v. Bieekill 318
Simmons v. Simmons 323
Sprague v. Craig 325
Southern v. Rexford 325, 326, 328
Simpson v. Black 327
Short v. Stone 328
Smith v Woodfine 828
Snowman v., Wardwell 328
Sherman v. Rawson 329
Sawyer v. Snelenberg 329
Seekit v. Sacitt 335
Sheets v. Andrews 337
Smith v. Strong 337
Stubbs v Page 337
Staats v. Ten Evke 337, 347
Scamour v. Harlan 337
Sweet v. Putrick 342
Swett v. Sprague 342
Sterling v. Peet 342
Sarpy v. New Orleans 342
Sumner v. Williams 347
Sparrow v. Kingman 349
Sherwood v. Barlow 350
Scott v Douglass 350
Schofield v. Homestead Co. 350
Schofield v Iowa Homestead Co 352
Stowell v. Bennett 353
Smith v. Jefts 353
Smith v. Ackerman 353
Stannard v. Eldridge 353, 354
St. Louis v. Bliss 354
Scribner v. Holmes 355
Smith v. Sprague 358
Staats v. Ten Eyke 358
Smith v. Hay 359
Sterling v. Peet 359
Seaman v. Harland 361
Sween v. Steele 361
Sadon v. Comstuck 370
Sanburn v. Chamberlain 370
Smith v. Theelen 380
LAW OF DAMAGES.
Section
Shulls v. Blackburn 382
Stearns v. Sampson 383
Spence v. Chadwick 384
Senior v. Armitage 284
Sturgis v. Warren 385
Selleck v. French 390
Sween v. Dodge 394
Sinag v. Cox 410
Smith v Dunlap 418
Swanson v. Cook 424
Simpson v. Griffin 428
Spears v. Clark 429
Shaw v. Woodcock 431
State v. Chrisman 433
State v. Baldly 434
Shaw v. Pratt 487, 439
Smith v. Bartholomew 437
Snow v. Chanler 437
Schock v. Miller 439
Stockton v. Stockton 439
State v. Matson 439
Story v. Johnson 439
Spear v. Ward 441
Standford Banking Co. v. Ball 441
Smith v. Townsend 441
State Bank v. Edwards 442
Spence v. Thomas 442
Shannon v..McMullen 442
Stewart v. Davis 442
Savings Bank v. Concord 442
Shehan v. Hampton 443
Stevens v. Campbell 443
Smith v. Clapton 443
Strade v. Hington 443
Simpson v. Blunt 443
Seber v. Tupp 444
Smith v. Bainbridge 446
Sweet v. Colgate 449, 452
Smeed v. Flood 450
South v. Howard 451
Sherman r. Chaplain Trans. Co 452
Stuart v. Wilkins 452
Salsbury v. Stainer 454
Sanders v. Taylor 454
Street v. Chapman 454
Sharon v. Marsher 454
Street v. Chapman 454, 455
Standenmire v. Willliamson 454
Shattuck v. Green 458
Smith v. Green 460
Singer v. Farnsworth 462
Smeed v. Ford 463
Smith v. McGuire 464
Simpkins v. Low 466
Straughter v. McRae 466
stewart v. Price 467, 475
-Shepherd v. Hampton ~ 468
INDEX: TO AUTHORITIES CITED.
Section
Seedam v. Jenks 468, 469
Startup v. Carterri 469, 476
Smeed v. Ford 474
Shepard v. Mil. G. L. Co. 474
Stewart v. Keith 479
Shaw v. Holland 479
Sinclair v. Talmage 487, 489, 495
Street v. Swine 484
Stumburg v. Gilchrist 485
Seoner v. Maron 486
Story v. N, Y. & Harlan RR.
487, 498
Seaton v. Municipality | 487, 498
Swift v. Harriman 489
Snelling v. Link 496
Schell v. Plume 500
Stewart v. Frazer 504
Stevenson v. Price 504
Storer v. Gowen 506
Stand v. Bell 506
Sodowiskiv. McFarland 506
Seranton v. Baxter 506
Sims v. Canfield 507
Spaar v. Holland 509
Sheck v. Strong 510
Smith v N H.R Co. 518, 514
St. L. &S.E.R R.v.Smock 514
Strahan v. Detroit 514
Shenk v. Phila. Steamb. Co. 515
Shepherd v. Eastern R. R. 515
Schiff v. N. Y. ect. R. RB. 518
Sturgess v. Bissel 520
Sherman v. Wells 520
Spring v. Haskill 520
S. P. O’Connor v."Garber 520
Sisson v. Cleve etc. R. R. 520
Smith v. Griffith 521
Scott v. Boston & N.W. Steam-
ship Co. 521
Stiles v. Davis 525
Stoneman v. Erie R. R. 528
Smithson v. U.S. Tel. Co. 531
Smeathend v. Ills. Tel. Co. 535
State v. Sausser 536
Squire v W. U. Tel. 539, 540, 542
Shields v. Wash. Tel. Co.
544, 546
Scotthorn v. S. S. R. R. 547
Smith v. Dickens 580, 552. 555
Stuart v. White 550
Spicer v. Hooper 550
Sainter v. Ferguson 550, 560, 563
Streether v. Williams 553
Studebaker v. White 555, 559
Sutton v. Howard 562
State of Ohio v. Harper 565
State of Mo. v. Sandusky 565, 566
XXXVIi
Section
Swan v. Steele 566
Sanders v. Hughes 567
Smith v. Story 567
Seay v. Greenwood 568, 569
Silsby v, Lucas 568, 574
State Bank v. Morrison ~ 569
Stadler Bro. v. Parmalee 569
Spring v. McGee 569
Shayer v. Bash 571
Sturges v. Knapp 573
Southbarr v. Crawford * 573
Stewart v. State 574
Schrader v. Wolfland 579
Single v. Schrader 579
Stockwell v. Byrne 580
Story v. O’Deal 580
Suydam v. Jenks 580
Sapris v. Little 581
State v. Gibson 588
Swan v. Steele 584
Shaffer et al v. State ex rel
Cox 585
Sea Ins. Co. v. Gavin 587
Strong v. Natally - 587
Sherwood v. Mut. Ins. Co. 695
Sloat v. Royal Ins. Co. 696
Seets v. Simel 708
Sherman v, Mitchell 711
Spencer v. McMasters 711
schul v. Pac. Ins. Co. 711
Sexton v. Brock 711
Smith v. Masten 715
Scherp v. Szadeczky 715
Sargent v. Dumston 716
Shute v. Barrett 720
Steadman v. Simmons 727, 728
a
Toledo, &c., R. R. Co. v. God-
dard 8, 175
Toledo, &c, R. R. Co. v. Thomas
8, 175
Tegarden v. Halfield 9
Tillotson v. Cheetham 13, 42
The Yankee v. Gallagher 14,
Tate v.O.& M R.R. Co. 17
Trademan v. Astor 23
The State v. Johns 23
Taber v. Huston 42, 44
Turner v. N. B. R. R. Co. 45
Taylor v. Railway Co. 47
Thorn v. Knapp 55, 310
Tulla v. Reed 60
Taber v. Hudson 61
Thrall v. Knapp 63-64
Thorn v. White 72
XXXViii
Section
Terlarge v. Colman
Taylor v. Moffatt
86
94, 277, 278
Taylor v. Aston 98
Turner v. Harvey 99
Tower v. Newcomb 102
Treebody v. Jacobson 104
Trigg v. Read 104
Tuttie v. Brown 112, 115
Turner v. Amble 136
Turner v. Turner 137
Tillotson v. Warner 138
Turner v. Ambler 141
Thompson v. Mussey 150
Tripp v. Thomas 150
Talley v. Corsie 150
Thayer v. Brooks 159
Terre Haute Gas Co. v. Teel 161
Tegarden v. Hatfield 163
Talley v. Ayres 175
T., W. & W. R. BR. v. Brennan 175
Timmons v.Cen. R. R. 176, 181
Tuff v. Warman 176
T., W. & W.B.R. v. Shuckman 178
T. R. R. Co..v. McGinnis 178
Trans Co. v. Vanderbilt 180
Thompson v. North Mo. R. R. 182
T., W. & W.R. R. v. Goddard 188
Tarwater v. Hannibal R. R. Co 190
Topeka v. Tuttle 202
Thebold v. R’y Pass. Ins. Co. 203
Taber v. Hudson 203
Terry v. Mayor, &c, of N. Y. 205
Telfer v North R. Co. 219, 220
Tilley, adm, v. Hudson R. R
Co. 221, 222, 226, 227, 228
True v. Plumer 232
Terwilling v. Wands 233
Tilk v. Parsons 233
Treat v. Bronning 234, 307
Teaff v. Huett 252. 253
Tardy v. Howard 256, 260
Tunnam y. Smart 256
Taylor v. Carpenter 273, 274
Taylor v. Barnes 355, 357
Talbot v. Whipple 296
Thompson vy. Lee 297
Thompson v. Bowen 301
Tryson v. Booth 306
Tuck v. Moses 309
Threadgood v. Litogot 311, 312
Thorn v. Knapp 312, 326
Thomas v. Shattuck 319
Thurston v. Conner 323
Tubbs v. Vandeck 329
Taylor v. McGuire 329
Taple v. Lebrun 337
Turner v. Livingstone 348
LAW OF DAMAGES.
Section
Terret v Taylor 350
Treft v. Adams 3538, 354
Thomas v. Stukel 356
Truel v. Granger 357, 362, 377
Thompson v. Guthrie 361
Tone v. Brorce 376
Thorne v. Dias 382
The People v. Leonard 383
Taff v. Hurst 385
Troutman v. Gouring 401
Tarpy v. Shepherd 405
Trowbridge v. Holeomb 418
The People v. Boswick 434
Tuckman v. Newhall 437, 438
Thorp v. Thorp 438
Thompson v. Adams 439
Towns v. Riddle 443
Taylor v. Davis 443
_Thompson v. Perrysville 444
Tyner et al. v. Stoop 445
Tishune v. Dever 450
Thompson v. Dowell 452
Taylor v. Maguire 462
Thornton v. Thompson 466
Trout v. Kennedy 477
Tice v. Sherman 482
Trothnap v. Barrett. 482
Thompson v Wood. 485
Thorp v. White 488
Thomas v. Dike 489
Trowbridge v. Barrett 489, 495
Tomax v. Baile 492
Trowbridge v. Sherman 496
Tharger v. Wright & Hutchins 504
Tracy y. Wood 505, 506
Thompkins v. Saltmarsh 506
Thompson v. Andrews 507
Treadwell v. Davis 509
Thayer v. Dante :
Thickstun v. Howard
The Pitts. & St. L. R. R Co. v.
Nash et al. 515, 517
Thomas v. Bos, & Prov. R. R. 517
Tourent v. Vaughn
Taylor v. Collier 520
T, W. & W.R.R. v. Hammond 527
The Gt North. R. v. Shepherd 527
Tyler v. U. S. Tel. Co. 531, 541
True v. International, &c. 534
535, 539, 540
Tel. Co v. Dryburgh 534
Tea v. Whittaker 550
Taylor v. Sandford 552, 554, 555, 559
Thaine v. Quanware 572
Thompson v. McNair 573
Trustees v. Southern Illinois 574
Tonge v. Watts 587
509
513
INDEX TO AUTHORITIES CITED.
Section
Taylor v. Dunbar 589
Trueblood v. Trueblood 704
Tapley v. McGee 704
T. H. Co. v. Vanetta 711
Treaner v. Donhue 711
Travier v. Boyer 715
Tare v. Summers 715
Tullidge v. Wade 715, 716, 717, 719
Tegarden v. Hatfield 727
U.
U. S.v. Ortega 58, 60
U.S. v. Colly 71
U. S.v. Levi 71
Underwood v. Linton 81
Unto v. Weaver . 91
Underwood v. Robins 97
U. 5. v Morgan 125
Underwood v. N.W. Scythe 127
Ulner v. Leland 137
Updegrover v. Zimmerman 234
U. S. Bank v. Chapin 390
Utica Ins. Co v. Toledo Ins.
Co. 434
Union Bank v. Gravenner 441
U.S. Exp. Co v. Rush 514
U.S Tel. Co. v. Gildersleeve
535, 536, 546
Usher v. Noble 592
Union R R, v. Hand. 722
Uniou Cent. R. R v Hand 724
V.
Vanderburg v. Truax 5, 193
Vanderburg v. Truax 6
Vance v. Erie R.R. 22, 152
V. J.B. Co. v. Patterson 54
Veedsburg R. R. v. Patten 54
Vancool v. Boughton 94
Varnersdale v Howard 104
Voorhees v. Earl 108
Vanderburgh v Lennox 124
Vinas v. Merchants, 152
Vedder v. Vedder 158
Vrooman vy. Lawyer 161, 162
Vaux v. Sheffer 167
Vanderplank v. Miller 172
Vere v. Lord Cawdan 180
Vaughan v. Melone 181
Vaughan v. Wood 205
Van. & T. H. R. R. v. Bowers 263
V. T.R. R. v. Henry 264
Van Wert v. Walley . 309
Veny v. Walkins 311
Vale v. Junction R. Co. 337
Vane v. Lord Barnard Gilbert 353
XXX1X
2 Section
Vanwagoner v. Vannortrand 355
Van Rensselear v Planter 359
Vernan v, smith 376
VanRensseler v. Jewett, 384
Vanhoover v. Logan 418
Vace v. Hunt 429
Viale v. Hoag 436
Vandevere v. Clark 458
Vartie v. Underwood 441
Van Allen v. IN. C R. R. 466
Varble v. Bigle 519
VanWinkle v. U.S. Mail Str. 525
VanBuren v. Digges 555
Ww.
Wadhour v. Meacham 6
Williamson v. Wes. Stage Co. 13
Wiley v. Keokuk: 13, 60
Wiley v. Manitoba 13
Wiley v. Smithman 13
Woset v. Jenkins 13
Walker v. Wilson 14
Whipple v. Walpole 14
Walker v. Smith . 14
W.& E. Canal v. Spear 18
Wheeler v. Cincinnati 19
Welch v. Bd. Supervisors 20
Whelen v. 2d Nat. Bank 22.
Watson v. Moore 27
Wall v. Mean 27
Wagner v. Hollum 28
, Woodman v. Wattingham 29
Wernor v. Queen 30
Whiting v. Hithcock 42, 44
Williamson v. Wes. Stage 47
Wily v. Howard 52, 346
Wheeler v. Randall 52
Wallace v. At. R. Co. 53
Welch v. Durand 54
Walker v. Erie RK. R. Co. 54
Wardrobe v. Col st. Co. 54
Wallace v. Moyorite 54
Wells v. Paget 55
Walker v. Smith 56
Williams v. Jones 60
Weaver v. Bush 60
Weigh v. Cumpton 60
Wadsworth v. Treat 61
West v. Horist 61
Watson v. Christy 72
Wil. & Enlto. R. R v. Dunn 73
Weedon v. Lindwell 75
Winter v. Henn 75, 86
Welton v. Webster 7
Williams v. Williams 77
Wilson v. Sprouls 79
xl LAW OF DAMAGES.
. Section
Welton v. Webster 79, 86
Welton v. Welton 80
Webbee v. Woort 84
Winter v. Woroot 86
Wells v. Barnard 86
White v. Nellis 86
Wilkin v. Handcock 87
White v. Campbell 88
Witny v. Elner 88
Woods v. -state 89
Wright v. Court 91
Williams v. Ghonester 93
Wright v. Court 93
WM oodkirk v Williams 95
Wilson v. Hock 96
Warrick v. Faulk 96
Woodruff v. Garner 98
Warren v. Daniels 98, 99
White v. Cudden 102
Whitmore v. South Boston
Iron Co. 111, 115
Woodward v. Shocker 2112, 115
Watson v. Morrison 112
Wheeler v. Randall 112
Wintz v. Morrison 113
Wright v. Roach 115
AW ilson v. Ellis 121
Woodruf v. Nealy 122
Williams v. Powell 123
Watson v. Lisborn 125. 206
White v. Marly 128
Whitebeck v. N. Y. C. R.R.
* 129, 313
White v. Mosely 129, 130
Walker v. Smith 129
Walter v. Post 131
Wood v. Buckly 134
Wood v. U.S. 145
Williams v. Taylor 145
Wilkinson v. Arnold 145
Wood v. Brekley 146
Weeks v. Fentham 147
Wheeler v. Nesbett 148, 151, 152
Wilkinson v. Arnold 150
White v. Tucker 150
“ebb v. Nichols 150
Wheeler v. Z. National Bank 152
Willard v. City of Cambridge 159
Wagner v Jermain 159
Wolf v. Chalker 161, 162
Williams v. N. A. R.R. 161
Wright v. Ramscot 163
Williamson v. Barrett 163, 167,168
Webster v. R. R. 171
M right v. Gaff 176
Wright v. Brown 177, 180
Wherely v. Whiteman 177
Section
Weaver v. Ward 181
Wilcox v. Watertown R. R. 183
Wait v. N. E.R. 188
Wright v. Malden ete. R. R.
185, 186
Waggoner J. in Isabel v.
Hannibal R. R. 188
Wright v. Gray 193
Walrath v. Redfield 193
Webb v. Watertown 197
Wade v. Leroy 203, 207
Wily v. Keokuk 203
Wheeland v. Lynch 205
Whitelue v. N.Y. Cent. R. R. 205
Wood v. Clapp 206
Whitford v. Pana R. R. 220
Willett v. Buffalo etc. R. R. 229
Wigmore v. Joy 229
White v. Nichols 230
Willion v. Gait 232, 233
Weston v. Dobinet 235
Wilson v. Noonan 235, 236
Wright v. Schoeder 235
Watts v. Frazer 236
Wasson v. Canfield ©236
Whitbeck v. N.Y. Cent. R. R.
246, 248
Whitfield v. Whitfield 246, 247
Whitfield v. Whitself 246
Wetherel v. Green 248
Whitehouse v. Atkinson 249
Whitney et al v. Lehmer 252
Wood v. Gaynon 253
Walls v. Johnson 256
Woodburn v. Cogdale 256
Warner v. Matthews 258
Waterworks v. Burkhart 262, 263
Warrick v. Smith 263
Water Com v Lawrence
Whitewater V.R. R. v.McC. 264
Whitman v. Boston & Maine
R. R. 264
W.&St. P.R.R.v.Denman 264
Whitewater Valley Co. v. Mc-
Clure 265
W.&St. P.R.R.v. Walden 265
Watson v. Pittsburg R. R. Co. 265
Whitmore v. Cutter 268, 269,
2
Wolf v. Burke ” 974
Walton v. Crowley 274
Waldo v. Wallace 278
Whipple v. Cumberland 285
Whittemore v Cutter 287
Wright v. Storm 289
Williams v. Mority 289
Waterer v. Freeman 289
INDEX TO AUTHORITIES CITED.
Section
White v Griffin 290
Wells v. Walting 290
Wislon v. Whitaker 290
Weller v. Baker 290
Weston v. Alden 293
’ Wadsworth v. Tillotson 294, 297
Walrath v. Redfield 296
Watts v. T. G. RB. Co.. 296
Walker v. Butz 297
Wadsworth v. Smith 297
Wilson v. Blackbird Creek
Manf. Co. 297
White v. Todd’s Valley Water
Co 297
Weaver v. Congey 297
Weaver v. Eureka 297
White v. Chapen 297
Watkins v. Peck 297
Walls v. Kinney 297
Wilber v Brown 297
Wheatley v. Baugh 297
Ward v. Neal 300
Weathersby v. Marsh 306, 307
Watts v. Frazier 306
Walcott v. Hall 307
Waithmore v. Weaver 307
Woods v. Anderson 307
Wellister v. DeTastet 309
Wallace v. Tellfair 309
Wetherel v. Green 313
Walker v. Ellis 318
Walker v. Ports 319
Walters v. Bristol 323
Wigham v. Coots 323
Wilds v. Bogan 323, 329
Weaver v Bockhart 324
White v. Thomas 325
Willard v. Stone 325
Wood v. Bellamy 328
Walen v. Lamon 329
Wells v. Pagett 329
Wharton x. Peters 8235
Wilson v. Foles 337
Wyman v. Ballard 342
Webber v Coussy 342
. Wager v. Schuyler 346
Wilborn vy. Beeman 348
Whiting v. Davy 348
Williams v. Thurlow 850
Wade v. Lindsy 350
With v Mamford _. 350
Wyman v. Ballard 353, 354
Whistler v. Hicks 353
Wyman v. Bregdon 354
Waldo v Long 354
Willett v. Burgess 356
Wadew. Comstock 358
Winslow v. McCall
Walker v. Moore
Wells v. Aberthany
Whiteside v Jennings
Wenne v. Kelly
Wamack v. McQuay
Williams v: Williams
Williams v. Obphian
Wilson v. Raybald
Whitney v. Sweet
Williams v. Warren
Wigglesworth v. Dallason
Whitney v. Broston
Ward v. Smith
Wheaton v. Pike
xli
Section
Whitewater Co. v. Hawkins
White v. Thomkins
Williams v. Jones
Watson v Robinson
Watrouse v. Clark
Wright v. Shelby
Worrell v. Munn
Ward v. Lewis
Webb v. Baird
Webb v. Hewett
Wood v. Britt
Walker v. McCullough
Ward v. Johnson
White v. Ault
Wallace v. Hudson
Wolf v. Rauning
Wilcox v Todd
Winston v. Yeargin
White v. Miller
Wood v. Waterville
Winder v. Diffenger
Whitehead v. Pitcher
Westfield v. Mayo
Wood v. Carvin
West v. Cunningham
Werner v. Lambard
Williams v. Conger
Waring v. Mason
Whitaker v Huesky
Wells v. Selwood
Witz v. Morrison
White v Miller
Woodward v. Powers
White v. Manly
418, 467,
437,
453,
455,
457,
West Gravel Road Co. v. Cox
Woodward v Hocker
West v. Wentworth
467,
Woodward v. the G. W. BR. Co
Wilson v. L. & Y. R. Co.
Wolf v. Studebaker
Worden v. Norris
West v. Pritchard
358
361
370
370
3874
376
376
379
381
383
383
384
385
409
410
411
475
420
429
433
433
433
434
43
436
438
488
441
441
441
441
442
444
444
445
445
448
452
452
452
453
454
453
454
459
475
459
461
461
466
476
474
474
474
475
476
xlii
Section
Williams v. Jones 480
Wheatly v. Mascol 482
Wiley v. Hack 482
Western v.Sharp 482, 484, 489,
491, 495, 496
Wright v. Faulkner 486. 495
Williams v Chicago 486
Wolf v. Howe 486
Wiley v. T. S. Dis. No.1 489, 495
Walcott v. Yeager 492, 495, 496
Wilson v. Graham 496
Woodbury v. Jones 496
West v. Murphy 504
Wilson v. Brett 506
Watkins v. Roberts 506
Woods v. McClue 506
Walcott v Ruth 507
Ward v. Sumner 507
Wash v. Pond 508
Wheeler v. Aubold 508
Wilson v. Little 509
Wheelock v. Wheelright 510
Willard v Bridge . 512
Walpole v. Bridges 514
Wigginsv. Boston R. R. 518, 526
Watkins v. Loughton 520
Weston v. Grand T. R Co. 521
Wilson v. Lancashire &c R Co 521
Whalon v. Aldrich 521
Williams v. Vanderbilt- 527
bi cs Union Tel. Co. v. Gra-
531, 535, pe 547
W eshington & N. O. Tel.
Hobson 5381, 539, 540, 542, 58
W. U. Tel. Co v. Crew
W.U. Tel. Co v. Buchanan 535, ae
Warm v. W. U. Tel. Co. 535, 536
W U Tel. Co. v. Casen 535
W. U. Tel. Co. v. Fentou 535, 541
W.U Tel. Co. v. Meek 535
Western Trans Co. v. Hall 536
W.U Tel. Co. v. Crum 536
Wyman v. Cochran 550
Wilson v. Greer 551
Watts v. Sheppard 555
Warren v. Steele 565
Walker v. Ford 565, 566
White v. Seely 565
Weld v. Clark 565
Wilson v. Root 568
Windship v. Clendening 572, 573
LAW OF DAMAGES.
Section
Washington v. Parks 573
Wallis v. Dilly 573
Wintzly v. Robinson 574
Watson v. Husson 576
Weler v. Farner 577
Wilson v. Stilwell 577
Weddle v. Stone 577
Westesvelt v. Smith 577
Walls v. Johnson 579
Wallace v. Clark 580
Waters v, Carroll 582
Warren v Franklin Ins. Co. 590
Wolf v. Home Ins. Co. 592, 693
Walters v. Merch. Life Ins. Co. 694
Waters v. Merchants’ Life and
Fire Ins. Co. 693, 695
White v. Rep Fire Ins. Co 696
Worster v. Prop’s Ca. Brice Co 711
Wells v. Sawyer 711
Walker v. Erie k. R. Co. 712
Y.
Young v. Austin 9
Yankee v. Gallagher 42
Yundt v. Rartuit 80
Young v. Bumpass 104
Yates v. Joice 122
Youmans v Padden 193
Young v. Bennett 235
Yates v. Miller 239
Young v. Loyd 246, 248, 318
Young v Willet 252, 580
Yokum v. Thomas 337, 358
Young v. Hill 416
Young v. McCreary 429
Yark v. Verplank 469
Young v. Smith 515
Young v. Poe U.S. 520
‘Young v. White 551
‘Yates v. Muller 718
Z
Zigler v. Powell
Zehner v. Kipler
Zahla et al. Mining Co. v. Isley 129
Zerping v. Mower
Zenkerd v. Newkink 329
Zehner v. Dale 467, 475
43, 96, 150, 151
CHAPTER I.
THE Discussion oF PRIMARY PrincrpLtes. THe Arm AND Op-
JECT OF THE Law in Assessing Damages. How it Acts. ,
Gives A ReMEDy To Every ONE WHO HAS BEEN INJURED.
Tue Derinitions or Damages. Tus Morrves or tHe Torr
FEASOR, WHEN ConsIDERED. Direct Damaces, REMOTE AND
SPECULATIVE. DiscRETION oF AJuRY. THE NatuRAL AND
PROXIMATE CONSEQUENCES ONLY CONSIDERED.
1. In entering upon the discussion of the measure of
damages we propose in the first place to notice some primary
rules that will assist’ the student in the investigation of the
subject. The law is made for the purpose of regulating the
conduct of men in society, and is enforced for no other purpose:
than to compel them to do what in good conscience and fair
- dealing they ought todo. And it adopts such methods and-
, uses such means as in its opinion will be the most efficient in’
compelling every individual to perform his whole duty. It
only acts for this purpose upon material matter, and never re-
sorts to moral suasion or religious precepts to accomplish its
object. From necessity it can only act on person and property.
Where one encroaches upon the rights of another or refuses
2 EGGLESTON ON DAMAGES.
to perform his legal duty, the law, on proper complaint, will
give the injured party an impartial hearing, and if a wrong
of sufficient magnitude has been committed it will investigate
the injury and then award such damages as will place the in-
jured party in as good condition as he was before the perpetra-
tion of the injury.
Damages have therefore been defined to be a recompense
or satisfaction given to the plaintiff for an injury received by
him from the defendant, or money given to a man by a jury
as compensation or satisfaction for some injury sustained.’ The
law aims to measure the damage by the injury. But so im-
perfect are human tribunals that this just and equitable rule
is seldom fully complied with. And it may be asserted with-
out casting the least reflection upon the judicial department
of the government that,if litigants fail to get complete com-
pensation it is rather an incident to the imperfection of hu-
man tribunals than the consequence of the inadequacy of the
standard set up by the law.
2. The Law Upholds Menin their Natural Rights. Human laws
are intended to uphold and protect men in the enjoyment of
those natural rights they possess as members of society. And
whenever an individual is interrupted in the enjoyment of
any of these rights the law gives him a remedy. From the
foregoing statements the importance of the law of damages is
readily seen. In fact the sole object of almost every indi-
vidual who commences an action in court is to recover dam-
ages.
3. The Common Law. When our ancestors emigrated to
the new world they brought with them the common law
which consisted of afew, broad and comprehensive principles
1 2 Greenleaf on evid., p. 209, sec. 253; Co. Lit. 257; 2 Blacks. Com.
438; Rockwood v, Allen, 7 Mass. 256; Bursy v. Donaldson, 4 Hall, 207.
INTRODUCTORY. . 8
founded on reason and natural justice, but they only adopted
so much of it as was applicable to their situation. In many
respects it was imperfect and failed to meet the wants and de-
mands of the people. But by the untiring energy of men of
great legal acumen these general principles have become more
precise and specific and better adapted to practical use. The
modification and expansion of the rules of common law have
been brought about by the decisions of the courts of the high-
est authority of this country and England. They have modi-
fied, limited and applied these principles to particular cases,
which have been acquiesced in until they have been engrafted
into and become a part of the common law of the country.
Owing to the elasticity of the rules of common law, when a
new practice or new course of: business arises, the rights and
duties of parties are not without a law to govern them, the
general consideration of reason and justice which underlie
the particular rules of that law will apply modified by the
courts to the new circumstances. Therefore, if the new busi-
ness or practice is such as to give rise to controversy and liti-
gation, they are soon settled by judicial expositions, and the
principles thus settled soon become. precise and practical
rules... And much of the law of damages has been the out-
: growth of the culture and forensic learning of men of recent
times.”
|
3. The Assessment of Damages not Uniform and Exact. Courts
and law writers have never been able to frame rules for the
assessment of damages based upon principles of justice and
equity that were definite, uniform and exact. And there is
much confusion and contradiction among the authorities at
this time in regard to what shall be the measure of damages
in certain cases.
1 Norway Plains Co. v. Boston & Maine R. R. Co., 1 Gray (Mass.) 137
*Vanwert v. Pecard, 2 Peter, U.S., 187.
4 LAW OF DAMAGES.
4. Direct, Remote and Consequential Dumages. When the in-
jury can be traced by a direct chain of events back to the first
cause, then we have what the law calls direct damages. But
when the first effect becomes a cause, which in its turn re-
sults in an injury, then there arises what is called remote dam-
ages. Public policy demands that there should be a limita-
tion of responsibility, and the law makers, in obedience to that
demand, have limited the liability to the natural, direct or
proximate result. It was an old maxim among the school
men “causa causantis causa est causati.* This makes the chain
of causation, by successive links endless." And this, in a
certain sense, is true, for no event can occur which may be
considered isolated and independent. Every event is the
effect of some cause or combination of causes, and in its turn
becomes a cause of many ensuiug consequences, more or less
immediate or remote.’
5. The Law looks to Particular Rules. The law looks to par-
ticular rules adapted to the rights and duties of all persons in
society in the common and ordinary concerns of actual and
real life, and on account of the difficulty of unraveling a com-
bination of causes and of tracing each result, as a matter of
fact, to its true and efficient cause, it has adopted the rule be-
fore stated of regarding the proximate and not the remote
cause of the occurrence which is the subject of inquiry. As
a general rule, damage, in cases of tort, is actual compensation
for the injury. But to this rule there are qualifications, the
law on some occasions inquires into the motives and intentions
of the tortfeasor, and draws a line of distinction between inten-
tional and unintentional injuries. Acts unaccompanied with
bad motives draw after them only their direct and mme-
diate consequences, and not those remote and speculative,
1Mable v. the City of Worcester, 4 Gray, Mass., 195.
2 Mable v. City of Worcester, supra.
INTRODUCTORY. 5
while grossly negligent or malicious acts may be the subject
of larger damages.®
6. The Proximate Cause. But in law the first efficient and
adequate cause, as well as any intermediate cause necessarily
following from the first cause is always held to be the proxi-
mate cause, unless some new cause, independent of the first
cause shall intervene between the first cause and the final in-
jurious result.© The proximate and remote causes do not have
reference to time nor distance, nor merely to a succession of
causes and effects. A wrong-doer is not merely responsible for
the first result of his wrongful act, but he is also responsible for
any succeeding injurious result which could have been fore-
seen by the ordinary forecast of mind. He is responsible for
any number of injurious results consecutively produced by im-
pulsion, one upon another, and constituting distinct, separate
events, provided they all necessarily follow from the first
wrongful cause.®
7. The Wrong-doer will not be Permitted to Apportion the Dam-
ages. No “wrong-doer can be allowed to apportion his own
wrongs; every person who does a wrong is at least responsible
for all mischievous consequences that may reasonably be ex-
pected to result under ordinary circumstances from such mis-
conduct; a man who officially presumes to interfere with or
make use of the property of another without his permission
is liable for all the consequences of such interference whether
he intended the injury or not.” Where one does an illegal or
sSeely v. Alden,61 Penn. st. 302; McKnight v. Ratcliff, 8 Wright, 168 ;
Daughty v. Bird, 10, P. F. Smith, 48.
9A.,T. & S. Fe R. R. Co. v Standford, 12 Kansas, 354; 15 Am. R., 362.
When one does an illegal or mischievous act in such a careless and im-
proper manner that injury to a third person might ensue, he is answer-
able in some form of action for all the consequences which may directly
and naturally result from his conduct.
Vanderburg v. Trex, 4 Davis, 467.
6 ' LAW OF DAMAGES.
mischievous act in such a careless and improper manner that
injury to a third person may probably ensue, he is answerable
in some form of action for all the consequences which may di-
rectly and naturally arise from his conduct. When the conse-
quences of an unlawful act are immediate, he who does the
unlawful act is considered the active doer of all that directly
follows. And when two parties have made a contract which
one of them has broken, the damages which the other party
ought to receive in respect to such breach of contract should
be such as may fairly and reasonable be considered as arising
naturally, i. e., according to the usual course of things, from
the breach of the contract itself, or such as may reasonably be
supposed to have been in the contemplation of the parties at
the time they made the contract as the probable result of a
breach of it."
8. The Law Requires a Man to be Active to Prevent Loss. The
law never permits a man to enhance his damages by his own
negligence and want of diligence. ‘Therefore where one has
been injured by the misconduct of another he must use or-
dinary effort and reasonable means to protect himself from the
consequence of the wrongful act, and he can only recover for
such losses as he could not thus prevent."
9. Exemplary Damages. Where the wrongful act is done
ina wanton and malicious manner and attended with circum-
stances of outrage or oppression it is thought that the jury in
"Hadley v. Baxendale, 9. Ecx. 341; Hille on Tort, 85; Broom’s Legal
Maxims, 228; Scott v. Shepherd, 2 Wm. Blackstone’s Rept. 692; Vander-
_ burgh v. Truax, 4 Devio, 364; Dent v. Toledo, etc., 59 Ill., 349; Atchison
R. R. v. Sanford, 12 Kansas, 341, Wadham y. Mearlow, 1 H. Black,
439; Davis & Garrett, 6 Bing. 716; Rigley v. Hunt, 5 Exep., 243; Alli-
son v. Chandler, 11 Mich. 542.
iJones, Admr. v. Van Pattent, 3 Ind., 107; The Cin. & Chi. R. R. Co.
v. Rodgers, 24 Ind., 103; Hamilton v. McPherson, 28 N.Y., 72; Shannon
v. Comstock, 21 Wend.. 461; Heckscher v. McCrea, 24. Wend,, 309;
Clark y, Morrigha, 1 Denio, 317; Locker v. Damon 17 Pick, 284.
INTRODUCTORY. 7
assessing damages for the injured party is not limited to sim-
ple compensation alone, but may assess against the wrong-doer
exemplary or vindictive damages, to punish the defendant.’
But exemplary damages is not permitted in an action for a
breach of contract, with very rare exceptions, perhaps in none,
except the single case of a breach of promise of marriage.’
10. Ligquidated Damages. Where the parties have by agree-
ment fixed the amount of damages that shall be recovered on
breach of the agreement, that amount can be recovered, pro-
vided the contract is not made to evade usury law, or for the
purpose of perpetrating a fraud or to oppress the defendant.’
11. No Recovery in Case of Contributory Negligence. In the case
of negligence the injured party, as a general rule, cannot re-
cover where he has contributed to theinjury. But to this rule
there are some exceptions that will be discussed under the
head of negligence.
12. - The Difficulty of Showing the Non-liability of the Defendant.
It is quite difficult to settle upon any set formula of
words that will in any case that may arise show
the non-liability of a defendant because of the acts of
the plaintiff in regard to the same injurious act. When
there is mutual negligence, ,if. the defendant cannot
avoid the accident by reasonable care and skill, the plaintiff
cannot recover. So when the negligence of the plaintiff
directly contributed to the injury he cannot recover. Where
negligence is the issue it must be a case of unmixed negligence
to justify a recovery, and if both parties by their negligence
t
ae
1 Post Chapter Exemplary Damages.
2Hay v. Gronorlele, 34 Pa., St. 9.
3 Field on Law of Damages, 22; Frazer v. Pecksly, 7 C. A. & Payne,
621,
8 LAW OF DAMAGES.
‘immediately contributed to produce the injury neither can
recover.!
13. The Complaint, The plaintiff when he commences his
cause of action generally files with the clerk, of the court his
complaint, in which he represents to the court the facts consti-
tuting his supposed injury or cause of action. In his com-
plaint the law conclusively presumes he has set out, every
grievance and injury that he has sustained by reason of the
wrongful act for which he sues. And he can only recover
damages for such injuries as he has set out in the allegations
of his complaint, whether his action is brought for a breach of
contract or in tort.?
But in proof of damages the plaintiff will not be confined
to the precise number, sum or value laid in his declaration
or complaint, nor is he bound to prove that he has sustained
injury to the full extent alleged.’
14. The Damages which Necessarily Arise can be Shown under the
General Allegations. Those injuries which necessarily result from
1 Toledo & Wabash R. R. Co. v. Goddard, 25 Ind. 185; Butter-
field & Forrester, 11 East. 60; The Evansville & Crawfordsville R. R. Co.
vy. Hiatt, 17 Ind. 102, Loften v. Voles, Id. 106; The Evansville & Craw-
fordsville R. R. Co. v. Loudermilk, ‘15 Ind. 120; The Teledo & Wabash
R. R. Co. vy. Thomas, 18 Ind. 215; Smith vy. Smith, 2 Pickering, 621.
?Brooks v. The Buffalo &c. R. R., 25 Barbour 600; Suydam v. The
Street Railway Company, 41 Barbour, 375; Runyen v. The Central R. R.
Company, 1 Duch., 558; Dascombe v. The Erie R. R. Company, 27 Bar-
bour, 221; Button, Adm’r v. Hudson R. R. Co., 18 N. Y., 248; Brown v.
Maxwell, 6 Hill, 592; The Cleveland R. R. Co. v. Ferry 8 Ohio, 570;
Clark v. Kimir. 4, E. D. Smith 21; Owen vy. The Hudson R. R. Co. 2
Bosworth. 374; 2 Hall v. Hall, 42 Ind., 585; Murch v. The Concord R.
R. Co., 9 Fort., 9; Moore y. The Central R. R. Co. 4 Zabrisky 268, 828;
The Evansville R. R. v. Durear, 28 Ind. 441; The Lafayette R. R. Co. v.
Sims, 27 Ind. 59.
8 2 Greenleaf on evid section 260; 6 Yeats, et al. vs. Reed, et al., 4
Black., 463; 2 Greanleaf on evid. sec. 254,
INTRODUCTORY. 9
the act of the defendant are termed general damages and may be
shown under the general allegations of the complaint, and the
demand for damages at the end. This is permitted on the pre-
sumption that the defendant is aware of the necessary conse-
quence of his own conduct, and therefore cannot be taken by
surprise in proof ofthem. The law alway’s raises a presumption
of damages when the evidence shows a violation of a right or
duty implied by law, and where the extent of the injury or
damages is not shown, the court will award nominal damages.
But when the damages are the natural consequence of the act
complained of. but are not the necessary result of it, they are
called special damages, and in order for the plaintiff to re-
cover for such damages they must be specified in his complaint.
If this is not done he will not be permitted to give evi-
dence of them on the trial.” .
15. The Jury at Common Law fixes the Measure of Damages. At
common law the jury is left to fix the the measure of damages
that the plaintiff shall recover, and when no amount is shown
by the agreement either expressed or implied, the verdict of
the jury will not be disturbed by the court, unless it is shown
that there were actually prejudice or corruption in assessing
the damages.1 The law in case of torts allows a jury a large
discretionary power in assessing damages. And unless there
has been a great abuse of that discretion a motion for a new
trial on account of ‘excessive damages will be overruled. Thus
it was said that new trials should be granted only in case of
tort “when the finding has stamped upon it a palpable disre-
gard of the rights of the parties and the indulgence of preju-
dice rather than a just view of the case. A verdict however
7 1 Chitty on Pleadings 328, 346, 347 (4 ed.)
1 2 Greenleaf, evid. sec. 255; Gellent v. Buckingham, Lofft R. 771,
Coup. 230; Day v. Holloway, 1 Jur. 794; Tegarden v. Hetfield, 11 Ind.
522; Young v. Tustin, 4 Black. 277; Reeves & Andrews, 7 Ind. 207;
Harper v. Miller, 27 Ind. 277; 2 Picquet v. McKay.
16 LAW OF DAMAGES.
to justify the intervention of a court should in the language of
many decisions on the first blush appear to be outrageous and
excessive.” ?
_ 16. Only the Proximate Consequences of the Breach can be Allowed.
The rule for the assessmeat of damages in case of a breach of
contract only permits the plaintiff to recover for the proximate
consequence of the breach. And there can be no allowance
made for loss or injury which is not the proximate conse-
quence of the breach. This excludes from the jury all remote
or possible losses which have no direct and necessary connec-
tion with the stipulations of the contract, or which depend
upon contingencies other than the performance of the contract
and which are therefore incapable of being estimated. Such
losses cannot be traced with any degree of certainty back to
the wrongful act or omission of him who has violated his en-
gagement. But this rule does not exclude such loss of profits
or advantages which must have resulted from a fulfillment of
the contract. They are a part and parcel of the contract itself
entering into and constituting a portion of its very element;
something stipulated for, the right to the enjoymenit of which is
just as clear and plain as to the fulfillment of any other stipu-
lation. The parties are presumed to have taken them into
consideration and deliberated upon them before the contract
was made, and were perhaps the only object that they had in
view in entering into the contract.
17. Hadly v. Bawendale.. The doctrine enunciated in the
famous case of Hadly v. Baxendale, decided by the English
1 Black. 465.
* Masterton v. Mayor of Brooklyn, 7 Hill 61; Adams Express Co. v.
Egbert, 36 Penn. stat. 360; Blarchord v. Ely et al. 21: Wend. 342; Flet-
cher v. Talun, 17 C. B. 21; Somes v. Wright, 115 Meap. 292; Griffin v.
Coluer, 16 N. Y. 489; Shepherd v. Milwaukee Gas Light Co., 15 Wis.
349.
INTRODUCTORY. ‘ 11
Exchequer Court in 1854, has been adopted by the courts of the
great majority of the states as being a correct exposition of the
rules of the common law. The court in that case held that
where two parties have made a contract which one of them
has broken, the damages which the other party ought to re-
ceive in respect to such breach of contract should be such as
may fairly and reasonably be considered, either arising natu-
rally, i. e. according to the usual course of things, from such
breach of contract itself or such as may reasonably be sup-
posed to have been in contemplation of both parties at the
time they made the contract as the probable result of the
breach of it. This rule is based on the presumption that
parties when they enter into a contract take into consideration
the damages that would naturally arise according to the usual
course of things by a breach of it. And both parties are sup-
posed to be cognizant of the result that is ordinarily produced
by the failure of a party to comply with the stipulations of
such contract. By this rule all remote or contingent losses
are disregarded and the recovery limited to the proximate con-
sequences of the breach.* |
18. Interest of the Plaintiff. The amount of the plaintiff's
damages in an action for an injury to property, will depend to
some extent upon the interest he had in it at the time of the
commission- of the wrongful act. Thus the owner of a free-
hold may recover for all injuries which permanently affect or
depreciate his property, while a tenant or one having only a
possessory right can only recover damages for an injury to his
use or enjoyment of the premises.°
There has been much controversy’ among the members of
: Hadly yv. Baxendale, 9 Exch. 341.
4 Adams Express Oo. v. Egbert, 36 Pa. st. 360.
Kep Kav. Sergeant, 7 W. & S 9; Schannable v. Kachler, 4 Cary
181; Rabb v. Mann, 1 Jones, 305; Seeley v. Alden, 61 Pa. st. 302
12 LAW OF DAMAGES.
the legal profession in regard to the measure of damages in
case of malicious and aggravated torts. It is contended on one
side that the true principle in all cases is that of compensation.
The advocates of this rule contend that it is broad enough to
furnish a remedy for even the most aggravated wrongs. That
under it proper allowance can be made for insult, outrage or |
indignity, for suffering of mind ag well as pain of body. Prof.
Greenleaf in his work on evidence says: “In the proof both
parties must be confined to the principal transaction com-
plained of and of its attendant circumstances and natural re-
sults, for these alone are put in issue.” * And he has been one
of the ablest advocates of the rule allowing only compensatory
damages, maintaining his position with great legal accumen
and solidity of argument.
On the other hand it is claimed that damages should not
only be allowed for the actual injury sustained, but that the
jury should be permitted in aggravated cases where the evi-
dence discloses the fact that the defendant was in the perpetra-
tion of the wrongful act prompted by bad motives, to blend
together the interest of the injured party and the interest of
the community and assess exemplary or vindictive damages
for the punishment of the wrong-doer or the defendant. This
doctrine seems to rest on no rule or principle back of itself, and
is unsupported by reason or the principles of natural right.
*And it is a matter of great surprise that one possessing the
breadth of thought and great forensic learning of Professor
Sedgwick, would be the zealous advocate of aaule that seems
to be so much in conflict with the principles of justice. But
whatever valid objection may be urged to this rule, it is now
recognized as law in almost every State in the Union.!
_ s 2 Greenleaf on evid. sec. 268,
1 Alabama—Mitchell v. Bellingly 17 Ala. 391; Duey v. McQueen, Id.
409; Parker v. Musi, 27 Ala. 480; Denaghu vy. Heath, 37 Id. 395; Ar-
NN OVA
INTRODUCTORY. 13
19. The rule allowing Exemplary Damages is being tested. But
the rule allowing juries to assess exemplary damages although
recognized as a part of the common law by the courts of last
resort both of England and this country for more than a cen-
tury is now being tested, and it is thought by many that it
will ultimately be overturned
20. Never was a Rule of the Gommon Law. It is hard to be-
lieve that it was ever a principle of the ancient and genuine
common law that men should be punished for crime in a civil
action. It is clear that damages were not originally designed
for such a purpose, because the ancient common law had its
civil and criminal courts which were kept separate and dis-
tinct. One was to award damages for injuries received, the
kansas—Olark v. Bales, 15 Ark. 452; Connecticut—Lindsy v. Bushnell,
15 Conn. 225; Hutiy v. Bown, 15 Id. 273; Dibble & Morris, 26 Conn.,
426; St. Peter’s Church v. Beach, 26 Conn. 365; Bastrom v Stone, 21 Id.
162; California—Nightengale v. Scammon, 18 Cal. 315; Dorsy v. Mem-
low, 14 Cal. 554; see statutes sec. 19; Delaware—Steamboat Co. v.
Wilden, 4 Harrington 228; Jefferson v. Adams, 4 Id. 321; [linois—
Groleli v. Morgram, 3 Scam. 372; McNamer v. King, 2 Gillai
432; Hawks v. Ridgway 33 Ill. 473; Chicago R. R. Co. v. Flog,
43 Id. 364; Peori—Bridge Ass. v. Looms, 20 Id. 235; Foster v. Nich-
ols, 28 Ill., 28 Ill, 486; Reeder v Purdy, 48 Id. 261; Reno v. Wilson, 49
ll. 95; Johnson v. Camp, 15 Id. 219; Booth v. Smith, 54 Id. 431 Iowa;
Hendrixson v. Kingsbury, 2 Ia. 379; Plumer v. Harbert B. Ia. 308;
Cochran v. Miller, 13 Ia 128; Denslow v. Vanhorn, 16 Ta. 476; Williamson
vy. Wes. Stage Co 24 Ia. 171; Indiana—Anthony v. Gilbert, 4 Black. 384;
Gurd v. Risk, 11 Ind. 156; Millsor v. Ilock, 17 Ind. 227; Little v. Lingle,
26 Ind. 168; Kentucky—Jennings v. Modox, 8 B. Monroe 430; Childs v.
Drake, 2 Met. 146; Bonson v. Green, 2 Duvall 234; Kentucky, &e. R. R.
Co. v Dells, 2 Burt 693; Kansas—Wiley v Keokuk, 6 Kan. 94; Wiley
v. Manatoba, Id. 111; Leavenworth R. R. Co. v. Rice, 10 Kansas, 466;
Mississippi—Chopper v. New Orleans R. R Co., 38 Miss. 242, 49 Id. 395;
Maryland—Baltimore, &c. R. R. Co v. Blocker, 27 Md. 277; Missouri—
Friedenstite v.. Kdmunson, 36 Mo 226; Buckly v. Knapp, 48 Mo. 152;
Carmen & Walton, 18 Id. 71; McKeon v. City R. R. Co. 42 Id. 79;
Maine—Peke v. Dellings, 48 Me. 539; Michigan—Hyatt v. Adams, 16
Mich. 180; Minnesota—Fox v. Stevens, 13 Minn. 272; Jones v. Rahilla,
16Id 320; North Carolina—Wiley v. Smithman, 8 Id. 236; Gelsett v.
"Allen, 10 Id. 67; New York—Tilloton v. Cheetham, 3 Johns, 56; Woset
14 / LAW OF DAMAGES.
other to punish the guilty.’ For a full discussion of the
question, see “Exemplary Damages.”
21. The Law Opposed to Litigation. The law is not friend-
ly to unnecessary ‘litigation and aims to conclusively settle all
matters of difference between the partics, growing out of the
injury complained of, by doing exact justice to both. These
are its ends and its rules are the means by which it accom-
plishes its ends. They are only of secondary importance, but
as “without them there would be no certainty in ju-
dicial action, and no accurate knowledge of personal rights
and obligations, these rules are adhered to,” although they
may work great hardship in certain cases. But when their
general effect becomes mischievous they are then set aside or
controlled by those general rules out of which spring the par-
ticular rule which has proven injurious. A particular law al--
ways implies a general one, and when the former comes in con-
flict with the latter it should cease to exist, from the fact that:
its only function is to aid the general law. This rule may be
illustrated by supposing that the general object of the law of
damages is to do justice between the parties, and for this pur-
v. Jenkins, 14 Id. 352; King v. Root, 4 Wend. 513; Biszer v. Maybell; 21
Wend. 144; Lift v. Centur, 3 Hill, 180; Lipe v. Esenler, 32 N. Y., 229;
Kendal v. Stone, 1 Sela. 14; Walker v. Wilson, 8 Bown 586; New Hamp-
shire—Whipple v. Walpole, 10 N. H. 130, Perkins v. Somelee, 43 Id. 220;
Fay v. Parker, 53 N. H. 342; New Jersey—Achison v. Erie R R. Co. 3
Broom, 254, Ohio—Atlanta E R Co. v. Dunn, 19 Ohio st. 162; Roberts v.
Means, 10 Id. 277 Penn.; Sommer v. Wilt, 48. & B., 19; North Carolina
—Greenville R. R. Co. v. Partow, 14 Rich. L. 237; Texas—Gordon v.
Jones, 27 Tex. 620; Tennessee—Rysom v. McGuire, 3 Head, 530; Jones
v. Turpin, 6 Haik. 181; Vermont—Ney v. Meriman, 35 Vt. 488; Wiscon-
sin—Picket v. Crook 20 Wis. 358; Manly v. Dunbar, 24+ Wis. 183; Hook-
er v, Nutor, Ia. 292. Andthe Supreme Court of the United States has
repeateely recognized the rule. Day v. Woodward, 18 Hourd 362; The
Yankee v. Gallagher, 1 McCall 467; Philadelphia R. R Co. v. Quigley,
12 How. 202; Gould v. Christianson, Blotchy & H. 507; Walker v. Smith,
1 Was. C. C. 153.
3 2 Parson on contracts, 171.
RM aS
Me
INTRODUCTORY. 15
pose it establishes certain rules for the assessment of damages
in an action of Trover, Replevin, &c. The rule est&blished in
the case of trover,is of such a charater that instead of
meting out justice between the parties it actually robs
one party for the benefit of the other. In such cases the
object of the special rule having failed it should be set aside or
so modified as to become an auxiliary to the general rule. The
rule should never be in the way of the end to be accom-
plished.”
2Arnold v. Cord, 16 Ind., 177; 56 Ind 569.
CHAPTER IL.
Piaintirr’s Inrerest. AN Unavutuorizep Act WitHout In-
JuRY GIVES No CAUSE FOR ACTION.
22. A Party Cannot Maintain a Suit Without Interest in the Sub-
ject Matter. As a general rule a party cannot maintain a suit
in court unless he has an interest in the subject matter in hti-
gation.1. If therefore the evidence shows that the plaintiff has
no right in the person or property injured or the contract that
has been violated. he cannot recover.’
23. The Common Law Rule. At common law, actions on
contract, whether expressed or implied, or whether by parol or
in writing or of record must be brought in the name of the
party in whom the legal interest in such contract is vested.
And the common law courts will not enforce mere equitable
rights.’
24. Action for Tort at Common Law must be Brought in the name
of the Person whose Legal Right has been Affected. At common law
actions for tort must, in general, be brought in the name of the
persou whose legal right has been affected, and who is legally
interested in the property at the time the injury was com-
mitted, for he is impliedly the party injured by the tort, and
whoever has sustained the loss is the person to call for compen-
INTEREST OF PLAINTIFF. “ 17
sation for the wrong done. An action for the injury to the
natural or absolute right of a person, as for an assault and bat-
tery, injury to health, reputation, and the like, can only be
brought in the name of the party immediately injured, and if
he dies the cause of action ceases and the remedy is gone.’ ¢
24. The Common Law Rule Abolished. In most of the States
the common law rule has been abolished, and the party having
the real interest must sue.°
25. The Plaintiff Cannot Recover for an Unauthorized Act Re-
sulting in no Damages. The plaintiff cannot recover even nomi-
nal damages for an unauthorized act that resulted in no in-
jury. In order for him to recover, the evidence must show that
there has been a breach of duty, or an injury to person or
property resulting in damages. No one can recover damages
unless some right has been infringed.’ But it is not to be un-
derstood that the law will interfere and restore every species
of loss that one individual may sustain by the act of another
1 Goodnight v. Goor, 30 Ind., 418; Morsher v. Allen, 16 Mass., 451.
® 1 Chitty, p 2. ¢
* A parent is entitled to the earnings of his child, and a suit for such
earnings must be brought in the parent’s name, 1 Pickering, 487.
41 Chitty pl. 3. .
"1 Chitty Pl 59-60. An action for injury to personal property is right-
ly brought in the name of ‘the owner at the time of the injury, alhough
it has been subsequently sold, and in the possession of a third party at
the commencement of the suit-~-Holly v. Huggerford. 8 Pick., 73; Boyn-
ton v. Williard, 10 Pick., 166. Under the codes of many oe the States
every action must be proseenteds in the name of the real party in inter-
est. Ind. St. by G & H. p. 34,5. 3; Gray v. Goodman, 9 Barbour, 657;
Seden v. Hepburn, 3 Sand 668; Tate v.0& M. R. R. Co., 10 Ind. 174;
Mahan.v. Brown, 13 Wend., 260.
5G. & H. Ind. 34, sec. 3; Gray v. Goodman, 9 Barbour, 657; Seden v.
Hepburn, 3 Sand. 668; Tate v. O. & M.R. R. Co., 10 Ind., 174; 6 Mea-
han v. Brown 13 Wend. 260. The code of procedure has abolished all
distinction between law and equity remedies and blended them into one
system combining or professing to combine the principle peculiar to
each. Getty v. H. R. R. a 6 Han. p 269.
18 LAW OF DAMAGES.
or others. There are many trifling injuries that are the result
of a breach of moral right and duty that the law fails to recog-
nize. It is only the legal injury that causes its machine to
move‘in the interest of the injured party. And this has given
rise to the legal maxim that damages absque injuria gives no
cause of action. The owner of property has a right to use it
in a prudent, reasonable manner and if by such use another
sustains damages, it is damnum absque injuria."
25. The Law Only Holds Tuan Liable for Voluntary
Wrongs. The law makes individuals liable only for voluntary
acts, and it charges no man with default where it is occasioned
by compulsion, and is not voluntary. And the fact that it is
impossible to do otherwise carries with it a privilege in itself,
and the party will not be responsible in damages.’
Rights of Adjoining Land Owners, If one land owner builds his
house so near the boundary line between him and his neigh-
bor that as soon as his neighbor removes the dirt on the oppo-
site side of the line up to the land of the plaintiff, the house
falls down, the plaintiff cannot recover, not having an ease-
ment over his neighbor’s land.?
Supervisors Not Liable. A Supervisor of a highway, whose
duty it is, under the law to keep in order the highways in his
distriag, cannot be held responsible ina civil action for a fail-
ure to perform his duty.*
"Sedgewick on dam. 28. There are many consequential injuries that
may happen to others from the legitimate use of one’s own property for
which there is no redress. W. & E. Canal v. Spear, 16 Ind., 441; 9 Ind.
59 Id. 448.
1 Broom’s Legal Maxims, p. 1-6.
aMeahan vy, Brown, 13 Wend. 1-6; Brown v. Roberts, 3 H. & N. 186;
Shagan y. Knowles, 6 H. & N, 454; Dodd v. Holms, 1 A. & E., 493;
ee alae v. Brown, 9 H. of Y. 503; Lashly v. Holbrock, 4 Page N.
* Field on Dam., 32.
INTEREST OF PLAINTIFF. 19
26. .A Municipal Corporation is not Liable for Failure to Perform
Legislative and Goevrnmental Acts. A municipal corporation is in
one sense a government, and possesses in a limited extent sov-
ereign powers, which in their nature are legislative or judicial.
The extent to which ‘it may be proper to exercise such, as well
as the mode of their exercise by the. corporation within the
limits prescribed by the law creating them, are of necessity
entrusted to the judgment, discretion and will of the properly
constituted authorities, to whom they are delegated. And, be-
ing public and sovereign in their nature, the corporation is not
liable in damages, either for a failure to exercise them or for
error committed in their exercise.‘
The Supreme Court of the State of Iowa, in a case where
the plaintiff brought an action to recover damages for the
death of his two chileren by small-pox, which he alleged he
caught by reason of the city of Lansing failing to take the
necessary precaution to prevent a spread df that disease, and
that he communicated the disease to his children, who died
from the effects of the same. In commenting on the question
as to the responsibility of the defendant, the court said: “The
principle that would hold the plaintiff liable for the negligent
act here complained of, would compel a city to respond in dam-
ages for the neglect of its police to suppress a riot; the failure
of its firemen to arrest a conflagration, and the negligence of
its physician to prescribe for a patient. It is impossible to
conceive of the endless complications and embarrassments
which such a doctrine would involve and the extent that pub-
lie interest would thereby suffer. It is safe to assume if such
were recognized as the law, that no town would voluntarily
4Brinckmyer v. Evansville, 29 Ind, 187; Rochester W. L. Co. v.
Rohester, 3 N. Y. 463; Floyd.v. N. Y. City, 3 N. Y. 369; Wheeler v. Cin-
cinnati, 19 Ohio St. 19; Col. of Med. v. Cleveland, 12 Ohio St., 375;
Smoot v. Wetumppa, 24 Ala., 112.
20 LAW OF DAMAGES.
assume corporate functions, and every industrial and commer-
cial interest would become paralyzed. The true doctrine is
that the powers conferred in the section we have been consid-
ering are of a legislative and governmental nature, for the de-
fective execution of which the city cannot be held liable. In
discharging these legislative functions the city acts as a quasi
sovereign and is not responsible for neglect or non-performance
of its officers or agents.” *
27. Whenever an Action is Brought for'a Breach of Duty the
Party Bringing it Cannot Recover unless he Shows an Interest in the
Contract. We think it may be laid down as a general rule
that whenever an action is brought for a breach of duty, the
plaintiff must show that he had an interest in the performance
of the duty, and that the duty was imposed for his benefit, and
the fact that a duty was imposed for the benefit of another or
for the public and his own advantage is merely incidental and
not a part of the design of the statute. He cannot recover for
a breach of that duty.®
28. The Owner of the Surface of the Land Owns Downward to
the Center of the Earth. The law gives the owner of the land
whatever is found below the surface, whether rocks or mineral
or earth or water, and he may dig and apply to his own use
whatever lies under his soil. It is his absolute property; and
the fact that in digging a well or mine on his own land he cuts
off the subteranean veins and the channels which supply an-
other’s well, gives no ground for damages. The injury is domnum
absque injuria." So when the stream is an artificial one and the
* Oges v. The City of Lansing, 35 Id. 495.
* Strong v. Campbell, 11 Barber, N. Y. 135; Welch’ y. Board of Super-
visors, 23 Id. 199; Smith v. Yosman, 37 Id. 89,
™N. A. & S. RR. Co. v. Peterson, 14 Ind. 112; Greencastle v. Hazelott,
23 Ind. 186; Acton v. Blundell, 12 M. & W. 324; Greenleaf v France, 19
Pick. 117; Rooth v. Juscall, 20 Conn. 033; Ellis v. Duncan, 21 Barber,
3
INTEREST OF PLAINTIFF. ‘ a1
works at its source which cause it are suspended whereby the
supply of water is cut off and ceases, the party benefited by
the flow through his land can recover no damages against the
party who causes its suspension.!
29. Where a Public Highway is Obstructed a Traveler may Enter
the Adjoining Land in order to Avoid the Obstruction. Where a pub-
lic highway is obstructed so that a traveler cannot pass along
he may enter upon the adjoining lands to avoid the obstruc-
tion. So in order to arrest the progress of fire a house may be
pulled down.’ In these cases the maxim salus populi suprema
lez applies, and it is damnum absque injuria.
30. Parties at Common Law. The rules of the common law
require the plaintiff in an action ex delicto to bring his suit
against the persons committing the injury. The general rule
is that all persons are liable to be sued for their own tortious
acts unconnected with or in disaffirmance of contract.’
An infant asa general rule cannot be sued in an ac-
tion in form ex contractu except for necessaries, yet he is
liable for all torts committed by him, as for slander, assault and
battery, &c.? A married woman is liable for torts actually com-
mitted, but she cannot be held liable for a trespass committed
230; Clatfield v. Wilson, 28 Vt. 49; Parker v Boston and Maine R. R.
Co.3 Cush. 107; Haswood v. Benton, 32 Vt. 737, Brown v. Allen, 25
Conn. 583.
1 Gavel v. Mearton, 19 C. B. N. 8, 732; Newell v. Brockwell, L. R. Ex.
1R.
2 Russell v. Mayor N. Y., 72 Demo. 461; Moyer vy. Lord, 17 Wed. 285,
2 Kent Com. 333; Field v. Desmoine, 39 Id. 579. .
11 Chittys P. 75, 87 R. 336, 337.
* Boe Ali Infancy. -Ifan infant hires a horse to go to a place agreed
‘on but goes to another place in a different direction, he will be liable in
trover for an unlawful concession of the horse; Homer v. Hinning, 3
Pickering, 492; Curtin v. Patton, 61 Serg. & Roub. 310.
29 LAW oF DAMAGES.
by prior or subsequent assent. A lunatic is not liable for
crimes committed by him, but the law holds him liable in a
civil action for all torts he may commit*
Corporations are liable by the common law in actions of
‘ trespass, trover trespass, on the case ex dilecto for torts com-
manded or authorized by them, and for this purpose the acts of
their agents are regarded as the acts of the corporation.’ It is
now pretty generally settled that corporations are responsible
for malicious prosecution.®
31. Responsibility of Parties for Joint Torts. There are some
torts which in law may be committed by several persons and
for which a joint action may be supported against all the par-
ties. And it is a general rule that all persons who aid, com-
mand, advise or countenance the commission of a tort by an-
other or who approve of it after it is done are liable if done
for their benefit in the same manner as if they had done the tort
with their own hands. Thus a person who is present at the
3 1 Chittys Pl. 75.
4 Ex parte v. Ligton, 14 Mass. 207. A non compos must be made a
defendant like other persons. Rogers v. Ellis, 1 Meigs 88.
5 Hawkins v. Duchess, &c. Steamboat Co., 2 Wend. 452; McCreary v.
Guardian of the Poor, 9 Ser. & Raub. 94; Lyman v. White River Bridge
Co. 2 Aik. 255, 2 Hill 573; Goodlove v. The City of Cincinnati, 4 How.
500, 514, Hamilton & Co. v. Cincinnati, &. Wright 603; Keanas v.
Schuylkill Bank, Wash. C. ©. 106; Beach v. Fulton Bank, 7 Conn. 487.
5 Goodspeed v. Kasthodden Bank, 22 Com. 530; Hypely v. Grover, &c.
Sewing Machine Co., 2 Wood 494; Fenton v. Wilson, Sewing &c. Co., 9
Phil. Pa. 189; Vance v. Erie R. R. Co. 32 N. J. 334; Green v. M. 0.7
Conn. But., N. J. 290; Whelen v. 2.N. B. 32 Sem. 469; Cooly on Torts,
120-121.
5 1 Chittys Pl. 85; also 37-42. An action for libel will be against two
or more if it be a joint act by all. Hasses v. Huntington, 2 Tyler 129;
Lancing v. Mont, 2 Johhs 382.
6 Judson v. Cook, 11 Barber 642. It was held in case of an injry toa
coach passenger by a collision of the coach not lighted with a turnpike
gate not safely fastened back. If both causes contributed to the injury
the plaintiff might recover of the driver and Turnpike Company; Dan-
ville, &c. v. Stewart, 2 Met, (Ky.) 119,
INTEREST OF DEFENDANT. 93
commission of a trespass aids, commands, advises, encourages
or excites the same by words, signs, gestures or looks, is in law
deemed to be an aider and abettor and liable as principal." If
one goes in aid of a person who commits a trespass though he
have no further part in it, he will himself be guilty of trespass.
32. Defendant on Contract. At common law where several
parties are jointly liable upon contract, they must all be made
defendants.» And when the contract is joint and several, the
plaintiff is at liberty to proceed against the parties jointly or
separately. If there are more than two parties to a joint and
several contract, the plaintiff must either sue them all jointly
or each of them separately.” Asa general rule where a party
will not be affected in any way by the result of the suit, he:
should not be made a party. If no judgment in any form can
be rendered against a party to the record, he should not be
joined either in action or contract or in tort.*
™ Brown v. Perkins, 1 Allen 89, 2 Hilliard on Torts, 293.
1 Clarke v. Allen, 15 Ark. 452; Herring v. Hoppock, 15 N. J. 423; Jud-
son v. Cook. 11 Barber, 642; Stone v. Dickenson, 7 Allen 26.
Trespass may be maintained against a person who merely carries
away the material of an old building that has been pulled down by a
trespasser. Dreyer v. Ming, 23 Mis. 434.
11 Chittys Pl, P. 41. McCall v. Price, 1 McCord 82; Tradesman’s v.
Astor, 11 Wend. 87; Peters v. Davis, 7 Mass. 257; Beach v. Hotchkiss, 2
Conn. 697. A covenant in a lease to two peysons as tenants in common
that the lessee shall pay. the rent, is a joint covenant notwithstanding
their several interests. Phillips v. Ronsall, &c. 2 Burn 138.
71 Chittys Pl. P. 43. Bangor Bank, v. Treat, 6 Geonl 207; The State,
&c. v. John 25 Ind. 82. :
3 Conklin v. Thurston and others, 18 Ind. 290.
CHAPTER HL.
EXEMPLARY DAMAGES.
Tur Ricut to Recover Exempiary DAMAGES QUESTIONED.
Ir NEVER WAS A PART OF THE ComMMON Law. THE worD
Damaces—its MEANING. THE JuRY SHOULD Not AssESs
DouBLE, PUNISHMENT. THE ARGUMENT IN FAVOR OF THE
Rute. OBJECTIONS STATED. THE Common Law. Dis-
CUSSION BETWEEN GREENLEAF AND SEDGWICK. AN ErFort
To RECONCILE THE CONFLICTING ViEWws. DAMAGES FOR
MENTAL SUFFERING HARD TO ESTIMATE. EXEMPLARY
DAMAGES ALLOWED AS A RULE IN THIS CouNTRY. THE DeE-
CISION OF THE SUPREME CouRT oF THE U.S. ConFLict
AmonG AUTHORITIES WHETHER IT SHOULD ALLOW WHERE
THE OFFENSE 1S CRIMINAL. AUTHORITIES ENUMERATED.
WHEN IT APPLIES To PRINCIPAL FOR CONDUCT OF HIS AGENT,
MASTER FOR CONDUCT OF HIS SERVANT, MASTER NoT Lia-
BLE FOR MALICIOUS TRESPASS OF THE AGENT. THe REta-
TION OF THE PARTIES. CoMMON CarrigRs’ LIABILITY.
OPINION OF THE CouRT OF AppEaALs or N. Y. WEALTH
oF DEFENDANT NoT CoNSIDERED. For wuat Injurigs Ex-
EMPLARY DAMAGES WILL BE ALLOWKD. FraupD, MALICE.
Gross NEGLIGENCE. BREACH OF PromisE. Dors nor AP-
PLY IN CASE OF AN INJURY BY A Domestic ANIMAL. Ex-
CEPTIONS To THIS RULE—INFANTS AND MARRIED WoMEN.
Tue NATURE OF THE OFFENSE SHOULD BE CONSIDERED.
33. The Right to Recover Exemplary Damages Questioned. The
right of the plaintiff to recover exemplary, vindictive or
'
HXEMPLARY DAMAGES. 95
punitive damages in a certain class of cases at Common Law
has been a source of much controversy among the members of
the legal profession for more than a quarter of acentury, and
courts of the last resort, both of England and this country have
” attempted in vain to reconcile the rule with the broad and
well-defined principles of that law.
34. The Rule Allowing the Assessment of Exemplary Damages
Never Was a Part of the Ancient Genuine Common Law. The rules
of the ancient genuine common law were founded on the prin-
ciple that each man should pay his just debts and compensate
those whom he hadinjured. And before they became confused
with statutory provisions could be traced back to primary
principles and reconciled with the rules of common sense, rea-
son and natural right. But the rule allowing the recovery of -
exemplary damages rests on no foundation back of the rule
itself.?
'
36. The Meaning of the word Damages shows it was Never In-
tended as a Punishment. The original meaning of the word dam-
ages furnishes very satisfactory evidence that at common law
the recovery of exemplary damages was not allowed. The word
damages is derived from the word demo, to take away. And,
at the time the rules of the common law were being collected
and fitted together, it never was used in the sense of punish-
ment. From this fact alone one can readily infer that it never
was the intention of the ancient common law to make the as-
sessment of damages a punishmeut for a crime, or that the
civil remedy provided for injuries received at the hands of the
tort feasor should be punitive to the wrong-doer as well as
compensatory to the’sufferer.. That this rule was not a part
28 Parson on cont., 171; Davis v. W. F. Coff., 7 N. Y., 191; Hay v. Par-
ker, 53 N.H., 342.
§ Hay v. Parker, 53 N. H., 342.
96 LAW OF DAMAGES.
of the ancient genuine common law, we think clearly appears
from the remarks of the Lord Commissioner in the case of Bal-
lew v. Bryant. He said: “I cannot help thinking that Lord
Keyon introduced into cases of this sort a principle as to dam-
ages extremely dangerous in its consequences. He considered
such damages not merely as calculated to repair the injury
done to the one party, but as a punishment to the other, and
as intended to correct the morals of the community. The
morals of the community have not been improved, and I am
afraid its feeling has been much impaired. A civil court,
in matters of a civil injury, is a bad corrector of morals; it
has only todo with the rights of the parties.”* From these
remarks, which fell from the Lord Commissioner on this occa-
sion, it seems as though the rule for the assessment of exem-
plary damages was engrafted into the rules of the common
law by Lord Keyon himself, and that it had not been recog-
nized as law prior to his time.
“i
37. The Law Aims to Restore the Loss. The law is made
for the purpose of upholding men in their natural rights, and
not for the purpose of robbing one for the benefit of another.
Where a party has sustained an injury by the wrongful act of
another, the law interposes its strong arm and takes a sufficient
amount of property from the wrong-doer and gives it to the in-
jured party as will recompense or pay him for the loss he has
sustained. This is in harmony with our notion of right and
justice. If one kills a horse belonging to another of the value
of one hundred dollars, the injury sustained is the loss of the
horse. If the wrong-doer at once pays the injured party the
full value of the horse or gives him a horse of equal value, it
would seem that the demands of justice ought to, and wouldbe,
satisfied. But under the rule allowing the recovery of exem-
plary damages, more than this can be recovered.
“Ballew v. Bryant, 1 Mass.. 317 to 337.
EXEMPLARY DAMAGES. 97
38. The Jury should not assess Damages. Aftér a jury has
‘ gone to the full length of adequate compensation for the whole
injury sustained by the plaintiff, then to permit them to com-
mence anew and assess damages to punish the wrong-doer at
their option, is allowing them to exercise a wide and danger-
ous discretionary power.‘
39. The Argument in favor of the Rule and the Reasons Assigned.
The basis upon which the advocates of the rule have seen
proper to rest their argument is that society has been injured
by reason of wrongful act. This proposition can be admitted
and yet there are very many well-grounded objections that
can be urged with great propriety against the rule.
1. Society or the State is a body corporated or politic, and
can sue like an individual. Its interest should not be confused
with the interest of its citizens; the two should be kept sepa-
arate. The rule should be to render unto the State-the things
that belong to the State, and unto the individual the things
that belong to the iudividual.”
2. If society has been injured, why should the injured
party be permitted to sue and recover damages for that injury.
It may be that he lives in a different neighborhood and per-
haps in a different State from where the injury. was received,
43 Parsons on contracts, 169.
1In Bodwell v. Swan, 3 Pick., 376, it was held that the repetition of
the word for which the action was brought or the uttering of words of
similar import might be given in evidence to show that the first writing
of the words was malicious. But the Court also declared that they could
not go further, and could not distinct calumny uttered by the defendant
to be given in evidence to prove his malice for speaking the words for
which the action was brought. See also Watson v. Moore, 2 Cush., 133.
In Wall v. Mease, 3 Bing., that other words than those in the declaration
could be introduced to show malice; but that damages must be given for
those words only for which the action was brought. McKeen v.
McLaughlin, 2.8 & B., 469.
28 LAW OF DAMAGES.
and will not be affected in the least by the shock that society
has sustained by the wrongful act for which he sues. Why
then should he be armed with the power of the State to punish
the offender and be permitted to put the afflicted penalty into
his own pocket. The State in all well regulated governments
is clothed with full authority and power to declare what acts
‘deserve punishment. The legislative bodies are delegated with
full power to define crime and to fix the penalty thereof, and
no other body or tribunal is delegated with such authority. If
a given act or class of acts deserve punishment, let the legisla-
tive authority of the State put it into the criminal code and
fix the punishment and not suffer it to be inflicted at the in-
stigation of the individual for his own benefit at the discre-
tion of a jury.’
‘x e
3. Society or the State is made up of a multitude of in-
dividuals, each of which contribute something towards its sup-
port. If, therefore, it is injured, each is compelled to assist in
making up the loss or repairing the injury. Then the rule
should be that whatever the State is able to recover from the
' tort feasor should go into the general fund for the benefit of all.
But under this rule allowing the recovery of exemplary, vin-
dictive or punitory damages, money is taken from the pocket
of the wrong doer and placed in the hands of a single indi- -
vidual.* This is wrong. It is robbing the public treasury to
enrich a citizen or perhaps a stranger.
Cro mwell vy. Wilkinson, 18 Ind. 365.
If there is a mass of general wrong which no one man can take hold
of it, the State can come with her criminal process. 3 Parson on con-
tract, 169; Burson v. Edwards, 1 Ind. 7; Rigdon v. Walcot, 6 Gil. & J.,
413; Wagner v. Hollum, 7 Gill. 296; Coffin v. Baithwait, 8 west 875
In fixing the compensation the jury have no right to give vindictive
or punitive damages against a municipal corporation. 52 Ill. 256.
* It appears to us that the true measure of damages should be limited
and measured by the rule to one full actual compensation for the injury
received, neither more nor less.
Professor Greenleaf in his work on evidence, saya: ‘“ Damages are
EXEMPLARY DAMAGES, 29
4. The welfare and happiness of the whole people of a
State demand that crime should be clearly defined and the
punishment fixed by law. In the dark ages laws were fre-
quently passed making crimes out of acts that were not crimes
when they were committed. But at this advanced age of
civilization men should be informed what acts are in deroga-
tion of the right of the people of the State and forbidden by
law. In ordinary cases of misdemeanor the legislatures of the
different States have defined the offense and restricted the power
of the court in the imposition of a penalty within certain
definite limits. Buta jury in a civil action have by this rule:
an unlimited discretion to determine the crime and to fix the
penalty or measure of redress demanded by the public interest.‘
This is permitting the jury to legislate in the criminal affairs
of the Government and to afflict such punishment on the
wrong doer as they may think proper, being unrestrained by
the laws of the State.°
5. There is no principle better established at common
law and none more fully recognized in the federal and state
constitutions than thaf an individual shall not be put in jeop-
ardy twice for the same offense. This rule so long recognized
only applies to the respective governments, but it serves to
illustrate a great principle that applies with equal force to a
double punishment for the same act by the state and federal
given as a compensation, recompense or satisfaction to the plaintiff for
an injury actually received by him from the defendant. They should
be precisely commensurated with the injury, neither more nor less, and
this whether it be to his person or estate.
All damages must be the result of the injury complained of whether
it consists in the withholding of a legal right or a breach of duty, legally
due to the plaintiff. 2 Greenleaf, sec. 253-254; Woodman v. Watting-
ham, 49 N. H. 387.
4 Daine v. Wycoff, 7 N. Y.191; Lord commissions in case of Ballew v.
Byant, 1 Mass. R. 817-337.
5 Hay v. Parker, 5 How. 435; Fox v. Ohio, 5 How. 435.
#
30 LAW OF DAMAGES.
courts.’ These constitutional provisions are merely a reitera-
tion of the rules of the common law, and it will assist us in
interpreting them by refering briefly to some of the rules:and
maxims of that law. One of the well recognized maxims of
that law is nemo bis nexari debet pro eadem causa. No man ought
to be twice tried or brought into jeopardy of his life or liberty
more than once for the same offense.’ That the principles
enumerated in these constitutions apply with equal force to
proceedings in both civil and criminal cases is too well settled
to admit of controversy... There is certainly no distinction be-
tween the two as to the application of the fundamental rule
from the fact that the plea of autrefois acquit or its converse in
a criminal case, or a plea of judgment recovered, or its con-
verse in a civil action would be a bar or full defense to an-
other action. The rule is recognized in almost every civil-
ized nation of the earth that when a matter has been once
litigated and brought to an end by the proceeding having
gone on to a termination, the verdict or jugdment shall be a
bar to the second trial or litigation upon the same matter.
The idea or rule is fully expressed by the maxim “nemo debet
bis nevari.” And means that a man shall not be tried again
for the same offense after a previous decision upon it.’
It is very clear that the rules of the common law
and these constitutional provisions prohibiting a double pen-
alty is applicable alike to civil and criminal cases making a
judgment. in one action a bar to another action founded on the
same cause. It follows logically therefore that punitive dam-
ages are a violation of the general principles of the common
law and these constitutional provisions, unless indeed they
6 See authorities above.
* Brooms Com. 992; Bird v. Dennison crim. case, 222.
1 Winsor v. Queen Law, R. 12 Q. B. 289.
" Windsor v. The Queen Law Rep., 120 R. 289; Fay v. Parker, 53 N. H.
342.
\
EXEMPLARY DAMAGES. 31
shall be subject to this condition that they cannot be given
when the defendant has been previously subject to a fine im-
posed by a criminal prosecution, and where exemplary dam-
ages have been allowed in a civil suit, then a fine cannot be
imposed for the same cause in a criminal prosecution. This
would result in the abolition of what is now looked upon as
the ambiguous, confused and absurd rule of double punish-
ment cloaked under'the name of exemplary damages.
It seems obvious that if the defendant is compelled
in a civil action to pay to the plaintiff a fine for the injury
that his wrongful act has done to the community, or as a pun-
ishment for his guilty act, together with the damages that the
plaintiff has sustained by reason of such act. That the pun-
ishment would be just as severe as though he had been in-
dicted, tried and convicted in the first instance by the State
and fined and afterwards compelled to pay the damages to the
injured party by reason of a civil suit. To illustrate: Sup-
pose that John Smith commits an assault and battery on
‘Thomas Ray. He is indicted by the State, tried and con-
victed and fined twenty dollars. Ray afterwards brings a civil
action against him for damages on account of personal in-
juries received by his beating. The case is tried, and the
jury finds for the plaintiff damages to the amount of one hun-
dred dollars. In these two suits-Smith is compelled to pay
the aggregate sum of one hundred and twenty dollars. But
suppose that before the State prosecution was commenced Ray
had brought his suit for damages. On the trial the court had
instructed the jury that they could assess against Smith a fine
or damage to punish him for his crime against society. They
assess exemplary damages for his punishment at twenty dol-
lars and the damages to the plaintiff for personal injuries at
one hundred dollars, making in the aggregate one hundred and
11 Fay v. Parker, 53 N. H. 342.
32 LAW OF DAMAGES.
twenty dollars. The punishment to Smith would be just the
same in each case. The amount is neither more nor less.
The money that is extracted from him by the law, whether
the punishment innures to the benefit of the individual or to
him and the State, would be just the same. In one case he
has paid to the State a fine, and to the injured party compen-
satory damages. In the other he has paid the injured party
compensatory damages and a fine.
But let us pursue the subject a little farther. Sup-
pose before Ray brings his suit for damages Smith is indicted
by the State, tried and convicted, and fined twenty dollars,
Ray then brings his suit for damages, the jury assess against
him as exemplary damages by way of punishment—twenty
dollars and one hundred dollars damages for personal injuries
to Ray. Noone would pretend to say that Smith had not
been fined or punished twice for the same offense. From these
illustrations it at once becomes apparent that innumerable
practical difficulties must be encountered, involving absurdi-
ties and contradictions disgraceful to the administration of the
science of law, and. in utter contempt of common law and
constitutional right and time honored principles of justice in
the attempt of courts or law writers to evade, conceal or har-
monize the incongruities resulting from an effort to recaver
damages in a civil action of tort beyond strict compensation.®
40. Common Law Issues. The pleadings at common law are
composed of written allegations of the parties terminating in
a single proposition, distinctly affirmed on one side and denied
on the other called the issue. And it is an established-rule
governing the production of evidence of universal application
that the “evidence must correspond with the allegation and
be confined to the point in issue”* When a plaintiff brings
5 Fay v. Parker. 53 N. H. 342.
* 1 Greenleaf on evid. sec. 50.
EXEMPLARY DAMAGES. 83
his suit to recover damages for an assault and battery, he does
not allege that the morals of the community have been in-
jured by the wrongful act of the defendant, but he simply re-
ports to the court his personal injuries and asks the court to
allow such damages as will fully recompense him for the in-
jury he has: received. The defendant comes into court and
denies by his answer that he committed the wrong complained
of andthat the plaintiff has not been damaged in the sum
alleged in his complaint. The issues to be tried are first, did
the defendant assault the plaintiff in manner and form as
alleged in the complaint, and if he did was the plaintiff
damaged. A jury is empanneled and sworn to try the issues
between the parties and a true verdict given according to the
law and evidence. The evidence is introduced and shows that
the defendant committed the wrong complained of, and that
the plaintiff had suffered great pain, &c., but fails to show
that the assault in any way disturbed the peace of the com-
munity. After the close of the trial the court instructs the
jury that if they believe that the defendant committed the
act ina bad spirit they may assess against him exemplary
damages by way of punishment. And the jury composed of
twelve men, in no way responsible for their verdict, after in-
demnifying the plaintiff for'the injury he has sustained, pro-
ceed as conservators of the public morals to go beyond the
issue to punish the defendant for his undefined crime against
society.’ They could with as much propriety assess under
the issues the amount of damages that one of the plaintifi’s
neighbors had received by a blow from the hand of the de-
fendant while the fight between him and the plaintiff was go-
ingon. Every rule of practice and pleading known to the
" Dain vy. Wycoff, 7 N. Y. 191.
fi
34 LAW OF DAMAGES.
common laws are violated in assessing exemplary damages as
a punishment.
41. Greenleaf and Sedgwick. The discussion of this ques-
tion a few years ago by Professor Greenleaf and Judge Sedg-
wick, attracted the attention of the legal profession. through-
out the country, aud it was a matter of great surprise that
men holding views so diametrically opposite should be able to
present such a formidable array of authorities in support of
their respective opposing theories. It was contended by Pro-
fessor Greenleaf that damages “are as a compensation, recom-
pense or satisfaction to the plaintiff for an injury actually re-
ceived by him from the defendant. They should be precisely
commensurated with the injury, neither more nor less, and
this whether it be to his person or estate. All damages must
be the result of the injury complained of. It is frequently said
that in actions ex delicto, evidence is admissable of facts and
circumstances which go in aggravation or mitigation of dam-
ages. But this it is conceived means nothing more than that
evidence is admissable of facts and circumstances which goin
aggravation or mitigation of the injury itself. The circum-
stances thus proved ought to ve those only which belong to the
act complained of. The plaintiff is not justly entitled to re-
ceive compensation beyond the extent of the injury, nor ought
the-defendant to pay to the plaintiff more than the plaintiff
is entitled to receive. Injuries to person or to the reputation
consists in pain inflicted, whether bodily or mental, and in
the expense and loss of property which they occasion. The
jury, therefore, in estimation of damages, are to consider not
only the direct expense incurred by the plaintiff, but the loss
of his time, his bodily suffering, and if the injury was wilful,
1 Fay v. Parker, 53 N. H. 342.
A jury may weigh every fact which goes to the plaintiff’s injury,
whether in mind, body or estate, but are not at liberty to consider facts
which do not relate to the injury itself nor to its consequence to the
plaintiff. In other words they cannot go beyond the issue.
EXEMPLARY DAMAGES. 35
his mental agony; also the injury to -his reputation, the cir-
cumstances of indignity and contumely under which the wrong
was done, and the consequented public disgrace to the plain-
tiff, together with any other circumstances belonging to the
wrongful act, and tending to the plaintiff’s discomfort. And
on the other hand they are to consider any circumstances of
recent and immediate misconduct on the part of the plaintiff
in respect to the same transaction tending to diminish the de-
gree of injury on the whole are fairly to be attributed to the
defendant. Where an evil intent has manifested itself in acts
and circumstances accompanying the principal transaction,
they constitute a part of the injury, and if properly alleged
may be proved like any other fact material to the issue. Thus,
in trespass for taking goods, besides proof of their value, the
inconvenience and injury occasioned to the plaintiff by taking
them away under the particular circumstances of the case,
and the abusive language and conduct of the defendant at the
time are admissable in evidence to the jury, who may give
damages accordingly. And evidence of improper language or
conduct of the defendant is also admissable upon proper alle-
gations in an action of trespass on the case or trespass quan
clausum regit, as constituting a part of the injury. And gen-
enerally, wherever the wrongful act of the defendant, was ac-
companied with circumstances of indignity and insult, wheth-
er in the time, place or manner, though they may not form a
separate ground of action, yet' being properly alleged they may
be given in evidence to show the whole degree of injury.” ”
The theory of Judge Sedgwick is that “where elements
of fraud, malice, gross negligance or oppression mingle in the
controversy, the law, instead of adhering to the system, or even
language of compensation, permits the jury to give what is
termed punitive, vindictive or exemplary damages. In other
22 Greenleaf on evid., sc. 253, 254, 266, 267, 272.
36 LAW OF DAMAGES.
words, blends together the interests of the society, and the ag-
grieved individual, and gives damages not only to recompense
the offender, but to punish the defendant.°
42. Recent Efforts to Reconcile. There has been some recent
efforts made by courts and law writers to harmonize the con-
flicting theories advanced by these two noted commentators on
the law of damages and even Mr. Sedgwick himself in a note
to page 38 of his treatise on damages, concludes that the differ-
ence between himself and critics is after alla little more than
a verbal one. The attempted effort to reconcile the conflicting
views of these jurists has been on the theory that Mr. Sedg-
wick, in using the words exemplary, vindictive and punitory
damages intends to convey the idea to his readers that certain
elements should be considered'by the jury in assessing dam-
ages in actions of tort, where the elements of fraud, malice,
gross neglinence or oppression are shown to have mingled in
the controversy. And that the only difference between him-
and Prof. Greenleaf is that one claims that the plaintiff in
such actions should have damages for physical and mental suf-
fering, and that damages for such injuries shall be called com-
pensatory damages, and the other thinks the plaintiff should
have damages for physical suffering, to be called compensatory,
and damages for mental suffering, to be called exemplary. If
this was the idea that Mr. Sedgwick intended toconvey by the
use of the words exemplary, vindictive and punitory dam-
ages, the controversy would then be reduced down to a ques-
tion of the propriety of the use of language or words.
But we can hardly presume that one so skilled in the use
of languages as Mr. Sedgewick would use words so carelessly.
The controversy has not been as to what rule shall prevail
$Sedgwick on dam. (5 ed.) 34.
“Field on the law of dam., p 70, sec. 73.
EXEMPLARY DAMAGES. 37
but what is the rule established by the common law. In
order then to arrive at a correct conclusion upon the disputed
point, we must push aside the rubbish and dig down to the
original bed rock upon which the rules of the common law
rests and ascertain as best as we can the origin of the word
damage. The word “damage,” in French, dommage. Latin, :
damnum from demo, to take away, signifies the thing taken
away—the lost thing which a party is entitled to have re-
stored to him, so that he may be made whole again. The word
damages is derived from the word “demo,” to take away, and
therefore is not derived from “ punio,” to punish. And when
used to signify money, which the plaintiff ought to recover,
damages is never nor in any sense synonymous or collatteral
to the term example, fine, penalty, punishment, revenge, dis-.
cipline or chastisement.’ In the formation of the common
law the civil and criminal practice were kept entirely separate,
and were not blended together under any circumstances. The
State was the complaining party in all criminal cases, and
civil cases were prosecuted in the name of the party having
the legal interest. The rule allowing the recovery of exem-
plary damages therefore has been the growth of more recent
time, for it was not a part of the ancient genuine common
law. Mr. Rutherford in his institute in commenting on the
question of damages, says: As the heirs of the criminal have
no claim to such goods as he loses by way of punishment, so
neither has the injured person. He has indeed a right to so
much of the criminal’s goods as will make him amends for the
damages which he has suffered, but no reason can be given
why he should have a right to more unless some positive law
has given him such a right, the ends which justify punish-
ment will by no means extend his claims any further than
this. The criminal by suffering in his goods may discourage
or prevent him from offending again, but a design to discour-
5 Fay v. Parker, 53 N. H., 342. 3 Parsons on cont. 171.
88 LAW OF DAMAGES.
age or prevent him from offending again can be no ground for
that person whom he has injured by offending once to claim
property in goods which he is deprived of. The ends of pun-
ishment may be answered by taking the criminal’s goods from
him, but these ends do not require that the property he loses
should be vested in the pereon whom he has injured.°
43. The Opinion of the Supreme Court of Iowa. The ques-
tion of exemplary damages was recently up before the
Supreme Court of the State of Iowa, in the,case of Hendrick-
son y. Kingsbury, which was an action for an aggravated as-
sault and battery, and was carefully considered by that learned
jurist, Justice Cole. In reviewing the authorities he took
occasion to notice the controversy between Professor Green-
leaf and Judge Sedgewick, and said: “The controversy on this
subject between Professor Greenleaf and Mr. Sedgewick may,
perhaps, after all the attention and discussion it has excited,
be found to be a controversy as to the terminology of the law
rather than to the extent of the right of recovery or the real
measure of damages.”
i
“That while the plaintiff can only recover com-
pensation, he is not confined to the proof of actual
peouniary loss, but that the jury may take into consideration
every circumstance of the act which injuriously affects the
plaintiff, not only in his property, but in his person, his peace
of mind, his quiet and sense of security in the enjoyment of
his rights; in short his happiness. But it must affect his
happiness and not his neighbors, and therefore to this ques-
tion alone the jury should be restricted. While Mr. Sedge-
wick holds that whenever the elements of fraud, malice, gross
negligence or oppression mingle in the controversy, the law
* Rutherford’s Inst. Book, 1, chap. 17, sec. 1, p 385. Fay v. Parker,
p 342.
1
HXEMPLARY DAMAGES. 89
‘instead of adhering to the system or even the language of
compensation, adopts a wholly different rule. It permits the
jury to give what is termed punatory, vindictive or exemplary
damages. In other words blends together the interest of so-
ciety and the aggrieved individual, and gives damages not
only to recompense the sufferer but to punish the offender.”
It is perhaps true that the broad and general language of the
tule as stated by Mr. Sedgewick, tends more to convey toa
jury the idea of unlimited and unrestrained power, jurisdic-
tion or control over the amount of their verdict than the rule
stated by Professor Greenleaf, ‘and that under that rule juries
would more frequently return verdicts based more or less upon
their passion and prejudice than under the other rule. For
instance the instruction as given in this case (omitting the
objectionable claim heretofore considered) would tend to con-
vey to the jury the idea of complete control over the amount
of their verdict, unrestrained by any legal rule whatever.
But suppose they had been instructed that in estimating the
amount of the plaintiff’s damages they would ascertain and
give—First, the actual pecuniary loss directly sustained as
the value of the clothing destroyed. Second, the consequen-
tial pecuniary loss as to the value of the time lost by the
plaintiff, the expense (if any) incurred for medicine, phy-
sician’s bill, compensation to the attendant and board while
sick and the like. Third, physical suffering consequented
upon the injury, including any temporary, protracted or per-
manent deformity, disability or disfiguring, as by scars or the
like. Fourth, the mental anguish, loss of honor and sense of
shame caused by the act of thé defendant, as by the exposure
of her naked person to the ‘public, the sense of wrong in-
flicted, insult, affected, the degredation felt and the like.
Fifth, injury to the business, reputation, social standing and
the like. It is not unreasonable to suppose that such an in-
struction would more certainly exclude passion and prejudice,
and that a jury would feel themselves more constrained to
40 LAW OF DAMAGHS.
limit their verdict to the compensation to the plaintiff for the
injury inflicted by the defendant, and at the same time would
render a verdict which would amply compensate for the injury
in every phase and manner wherein it could operate. And,
indeed, it seems tous under such instruction the verdict would
be far more likely to approximate.to justice and to exclude
passion and prejudice, than under a general instruction as
given by the court in this case and justified by the rule laid
down by Mr. Sedgewick, and sustained by the general current
of the authorities. And yet it is doubtless true that such an
instruction might mislead and confuse a jury, and they would
not in any event have any pecuniary standard by which to
measure the damages under the third, fourth and fifth subdi-
visions of instruction as specified.” "
44, Damages for Mental Suffering Hard to Estimate. The
fact is obvious to every one that it is very hard to estimate
damages for mental suffering, public disgrace and physical
pain by a money standard. At best it can only be a conject-
ure. But it would be a monstrous wrong to close the doors of
the courts against the recovery of damages in such cases. The
task of assessing the amount of recovery or damages must
then rest on some one, and the law has, we think, wisely placed
the responsibility on the jury. The question then arises shall
the jury, clothed with this responsibe power, be circumscribed
by certain rules or left free to exercise their own discretion.
The history of the past demonstrates that the passions of the
human mind very frequently dethrone the judgment and
shape the conduct of individuals. And that the interest of
society demands that there should be restriction and limita-
tions thrown around us in every position in life, and especi-
ally is this the case when we are called upon to estimate the
damages that one has sustained by an aggravated injury at
the hand of another.
1 21 Iowa, 379,
HXEMPLARY DAMAGES. 41
We think, therefore, that the rule laid down by Judge Sedge-
wick, and which is adopted by the courts of the majority of
the States allows a jury too wide a discretionary power, and is
calculated to confuse and mislead their minds in a way that
will reflect no credit on the judicial department of our gov-
ernment.
45. The Rule is Adopted as the Law in this Country. But
notwithstanding the many well grounded objections that have
been urged against the rule allowing the assessment of exem-
plary damages, it’is now upheld by the decided weight of
authority, and exemplary damages may be recovered in all
cases resting on fraud, malice, gross negligence or oppression.’
46. The Decision of the Supreme Court of the United States. The
Supreme Court of the United States, in commenting upon this
question, says: “It is a well established principle of the com-
mon law, that in an action of trespass, and in all actions upon
the case for torts, the jury may inflict what are called exemplary,
vindictive or punitive damages upon the defendant, having in
view the enormity of the offense rather than the measure of
compensation tothe plaintiff. We are aware that the proprie-
ty of this doctrine has been questioned by some writers, but if
repeated judicial decisions for more than acentury are to be re-
ceived as the best exposition of what the law is, the question
will not admit of argument. By the common as well as by the
' The assessment of damages is a matter which must be unavoidably
in a great measure left to the discretion of a jury. It is proper for them
to take into consideration all the circumstances under which a trespass
has been committed, and wherever malice, insult or deliberate oppres-
sion has been an ingredient in the wrongful act, to award in addition to
the actual loss sustained, such exemplary damages as shall tend to pre-
vent a repetition of the injury. Anthony v. Gilbert, 4 Black. 348;
Bracegirdle vy. Oxford, 2M. & 8.77; Merser wv. Harug, 5 Iowa 442; Sears
v. Lyons, 2 Stack 317; Wait & Jenks. 14Johns 352; Churchill v. Watson,
5 Day 140; Mey v. Bohlfin. 44 Ind. 238; Stimpson v. Railsord & Co. 2
Wallace jun. 264,
49 LAW Gf DAMAGES,
statute law, men are often punished for aggravated misconduct
or lawless acts by means of civil action ‘and the damages in-
flicted by way of penalty or punishment given to the injured
party. In many civil actions, such as libel, slander, seduc-
tion, &c., the wrong done to the plaintiff is incapable of being
measured by a money standard, and the damages assessed de-
pend upon circumstances, showing the degree of moral turpi-
tude or atrocity of the defendant’s conduct, and may properly
be termed vindictive rather than compensatory. In an action
of trespass, where the injury has been wanton and malicious
or gross and outrageous, courts permit juries to add to the mea-
sure of compensation of the plaintiff, which he would have
been entitled to recover had the injury been inflicted without
design or intention, something further by way of punishment
or example, which has sometimes been called smart money.
This has always been left to the discretion of the jury as the
degree of punishment must depend on the peculiar circum-
stances of each case.” *
It is a well settled doctrine of the common law, though somewhat
disputed of, late, that a jury in an action of trespass or tort, may inflict
exemplary or vindictive damages. Stimpson v. Railway Co., 2 Wallace
Sur. R. 164,
3Horace H. Day v, W. James Wadsworth and others, 13 Howard (U.
8.) 3634; Huchel v. Money, 2 Wilson, 205; Mesit v. Havey, 5 Iowa, 442;
Sears v. Lyon, 2 Starkie, 282; Doe v. Felleter, 13M. & W , 50; Beasmore
v. Carrington, 2 Wilson, 244; Enoble v. Myers, 6 N. H. 54; Tellatson v.
Chusthom, 3 Johns, 56 and 64; Pike v. Dilling, 48 Me., 539; The Yankee
vy. Gallagher, 1 McAIl. 469; Symore v. McCormic, 16 Howard, 480-489;
Parker v. Costen, 4 McClam, 462; Philadelphia &c., R. R. Co. v. Quig-
ley; 21 Howard. 202; Sutton v. Mandville, 1 Cranch Cf., 187; Dibble v.
Moris, 26 Conn., 416; Dean v. Blackwell, 18 Ill., 336; Dewaugh v. Heath,
37 Ala., 595; Kuntz, et al., v. Stewart, et al., 54 Ind., 178; Cleghorn v.
The New York Central & Hudson River R. R. Co., 56 N. Y., 44, 15 Am.
R. 375; Taber v. Huston. 5 Ind., 322; Mercer v. Butler, 14 Ind., 479;
Nassaman v. Rickert, 18 Ind., 350; Humphries v. Johnson, 20 Ind., 190;
Meyer vy. Bohlfing, 44 Ind., 238; Whiting v. Hitchcock, 4 Denio, 463;
Grobe v. Margrave, 3 Scammon, 495; McName y. King, 2 Gilman, 432-
436; Smith v. Sherwood, 2 Texas, 460.
HXEMPLARY DAMAGES, ‘48
There are many other authorities that hold to the same
doctrine.‘
47. Should Exemplary Damages be Allowed when the Offense
is Punishable by the Criminal Court. There is a great conflict
in the decisions of the courts of the different States as
to whether the rule allowing the assessment of exemplary
damages should apply in those cases where in addition to the
civil remedy allowed the injured party, subject the offender to
a State prosecution. The Supreme Court of the State of In-
diana in the case of Taber v. Huston, says: “But there is a
class of offenses the commission of which in addition to the
civil remedy allowed the injured party, subjects the offender to
a State prosecution. To this class the case under considera-
tion belongs, and if the principle of the instruction be correct,
Taber may be twice punished for the same assault and battery.
This would not accord with the spirit of our institution. The
Constitution declares that no person shall be twice put in
jeopardy for the same offense, and though that provision may
not relate to the remedy secured by civil proceeding, still it
serves to illustrate a fundamental principle inculcated by
every well regulated system of government, viz: That each
violation of the law should be certainly followed by one appro-
priate punishment and no more. We think the jury had no
right as charged by the Circuit Court to give such additional
By
4 Whenever the injury complained of has been inflicted maliciously
or wantonly and with circumstances of contuinely or indignity, the
jury are not limited to the ascertainment of simple compensation, but
may give the plaintiff punitive or exemplary damages. Philadelphia R.
R. Co. v. Quigley, 21 Howe, 203; Dibble v. Morris, 26 Conn.,16; Dean v.
Blackwell; 18 Ill., 403; Baltimore &c., R. R. Co. v. Blocker, 27 Md., 277;
Bell vy. Marion, 27 Miss., 68; Hopkins v. Atlantic &c. R. R. Co., 36 N. H.
9; Wallace v. M. J. R. R., N. Y., 2 Holt, 440; Smith v. Wunderlich, 70
Ill, 426; Jones v. Jones, 71 Ill., 562; McCarthy v. Niskin, 22 Minn.. 90;
Storm y. Green, 51 Miss., 103; Memphis & R. R. Co. v. Dunlap, 56 N.
H., 456; Zigler v. Powell, 54 Ind., 173. :
44 LAW OF DAMAGES,
’ s
damages as would tend to prevent such conduct and give peace
and security to private rights in general.”° There are quite
a number of of authorities that uphold this doctrine.’
48. Authorities that Hold the Other Way. But there are
quite a number of authorities that hold the other way. The
Supreme Court of Vermont in commenting upon this question
makes use of the following language: “The fact that ina
civil action founded on a criminal act the guilty party has
been compelled to pay exemplary damages to the party in-
jured on account of the act, would be no bar to a prosecution
for the same act, nor to any part of the fine imposed by law
upon such offense. Neither should the liability to nor the
actual imposition of a fine in a criminal proceeding bar any
portion of the liability in a civil action for the same act.” *
49. Principal and Agent. It is not well settled by the
authorities whether the rule allowing the assessment of ex-
emplary damages applies to the principal for the wrongful act
of his agent while in his employ. But there are quite a num-
ber of decisions that hold that the principal cannot be im-
mersed in exemplary damages for the torts of his agent unless
he is culpable, but his culpability may be inferred from cir-
cumstances. It may be laid down however as a settled rule
that the principal is not liable for exemplary damages for the
gross negligence or the wilful wrongs of his agent unless he
6 Taber v. Huston, 5. Ind. 322.
' Whitney v. Hitchcock, 7 Denio (N. Y.) 461; Austin v. Wilson, 4
Cush, 273, 9 Law Rep. 529, 10 Law Rep. 238; Nassaunon v. Rickets, 18
Ind. 350; Humphries et al v. Johnson et al, 20 Ind. 190; Butler v. Mer-
ser, 18 Ind. 279; Fay v. Parks 53 N. H. p. 342; Hendrickson v. Kings-
bury, 21 Iowa 379.
“ Hoodly v. Watson, 52 Vet. 289; Cook v. Ellis, 6 Hill, 466; Fry v.
Bennett, 4 Dur. 247; Roberts v. Mason, 10 Ohio (N. 8S.) 277; Klopfer v.
Bromane, 26 Wis. 472; Hendrickson v. Kingsbury, 21 Iowa 379; Gar-
land v. Wholeham, 26 Iowa 189.
EXEMPLARY DAMAGES. 45
has consented to or authorized or ratified his agent’s acts." We
will now notice the responsibility of the master in exemplary
damages for the wrongs of his servant.
50. Master and Servant. A master is responsible ordina-
rily for the consequences resulting to others from negligence
or want of skill in which his employes do his business. This
responsibility results from duty which he owes to others as a
member of the community to employ careful and skillful ser-
vants to the end that his fellow men may not suffer by the neg-
ligence or ignorance with which his business is done. This
is but a reasonable rule easily fulfilled, and no one should com-
plain of the law which only requires the performance of that
duty which the rights of their persons demand.‘
51. The Master is Not Liable for Malicious Trespasses of the
Servant. The master is not liable however for the wilful and
malicious trespass of the servant not commanded or ratified
by the master, but evidently perpetrated to gratify the private
hate or malignity of the servant, under mere color of discharge
of duty which he has undertaken for hisemployer. But it is
not to be inferred from this that the master is never liable for
the wilful malicious acts of his servant unless he has directed
those specific acts to be-done. The rule is not so broad and
comprehensive as that. If the act of the servant, was neces-
sary to be done to accomplish the purpose of the servant’s em-
ployment, or if it was essential as a means to attain the end
directed by the master and was intended for that purpose, then
it will be implied in the employment, and the master will be
liable though the servant may have executed it wilfully and
* Cadwell v. N. J. Straw B. Co. 47, 282; Mendelshon v. Anchor Light
Co. 40 Cal. 657; Turner v. North Beach R. R. Co. 34 Cal. 594; Hill v,
The N. O. & Opelousa, &c. 11 La. 292.
4 The Evansville & Crawfordsville R. R. Co. v. Baum, 26 Ind. 70.
46 LAW OF DAMAGES.
maliciously. But when it is unnecessary to the performance,
of the master’s service and not really intended for that pur-
pose but is committed by the servant merely to gratify his
own malice, though under pretense of executing his employ-
ment it is not done to serve the master, and is not within the
scope of his employment and the master is not liable.*
52. Courts and Juries in Assessing Damages Should Inquire
Into the Relation of the Parties. In arriving at a conclusion as
to the liability of the master for the torts of his servant—the
court or jury should not fail to inquire into the relation of the
parties. A passenger on board a stage coach or railroad car
and a person on foot in the streets of a town or city or in the
public highway, do not stand in the same relation to the car-
rier. Towards the one the liability of the carrier springs from
contract, expressed or implied, and upheld by an adequate
consideration. Towards the other he is under no obligation
but that of justice and humanity. Hence a passenger who is
injured by a servant of a carrier may have a right of action
against him when one not a passeng:r for a similar injury
would not."
58. Carriers’ Liability. The ground of the carriers’ liabili-
ty may be briefly stated thus: The law requires the common
carrier of passengers to exercise the highest degree of care that
human judgment and foresight are capable of, to make his
passenger’s journey safe. Whoever engages in business im-
pliedly promises that his passengers shall have this degree of
care. In other words the carrier is conclusively presumed to
®The Evansville & Crawfordsville Railroad Company v. Baum, 26
Ind. 70; Gregory v. Piper, 9 B. & C. 591; Croft v. Alison, 4 B. & Ald.
590; McManus v. Crechet; 1 Eart. 106.
“' Band v. Railroad, 8 Barber, 368; Angle and Amers on Corporation,
388, p. 404; Goddard y. Grand Trunk Railway Co. 57 Maine, 202; Rail-
road y. Finny, 388; Railroad v. Vandiveer, 42 Penn. stat. 368.
EXEMPLARY DAMAGES. 47
have promised to do what, under the circumstances the law re-
quires him todo. If the passenger does not have such care,
_ but on the contrary is unlawfully assaulted and insulted by
one of the persons to whom his conveyeance is entrusted, the
earrier’s implied promise is broken, and his legal duty is left
unperformed, and he is necessarily responsible to the passen-
ger for the damages he thereby sustains. The passenger’s rem-
edy may be either in assumpsit or tort, at his election. Inone
case he relies upon a breach of the carrier’s common law du-
ties in support of his action, and in the other upon the breach
of an implied promise.
54. The Rule Applies to Corporations. The authorities are
not uniform as to whether the rule allowing the assessment of
exemplary damages should apply to corporations for the torts
of their agentsor servants. But the weight of the more recent
authorities seem to be much inclined to extend the rule to such
artificial persons the same as to an individual? And it may
now be considered settled that where the injury complained of
has been inflicted maliciously or wantonly and with circum-
stances of contumely or indignity, the jury are not limited to
the ascertainment of simple compensation for the wrong com-
mitted against the aggrieved person. But the malice means
*
*Hopkins v. The A. & St. Lawrence R. R. Co., 36 N. H., 9; Taylor v.
The Railway Co., 48 1d. 304 to 308; ‘Goddard v. The Grand Trunk R. R.,
57 N. H., 202; Redfield on Railways. 515 et sq report in American Law
Regs., vol. 10, p 17; Sherman and Redfield on Neglect, 600; N. 0., J. &
Great Northern R. R. Co. v. Patton, 36 Miss., 242; Same v. Bailey, 40
Miss , 390; V. J. R. R. Co. v. Patton,31 Miss., 156; M. & C. R. R. Co. v.
Whitfield, 44 Miss., 466; L. C. & Lex. R.R. Co. v. Dunn, 19 Ohio st., 162;
Pitts. & Ft. Wayne R. R. Co. v. Shumer, 19 Ohio st , 157, 57 Pa. st. 339;
B. & O. RB. R. Co. v. Bloocher; 27 Md. 277; Williamson vy. The West Stage
Co., 24 Iowa, 271; French & Co., y. Coe, 4 Green., 555; Ch., Rock I. &
& St.L v. McKean, 40 IIL, 218; iG, R.I. & P. R. R. Co. v. Harris, 57
IL, 59; Spirce v. G. & N. W. R. R., 29 Wis., 580; Milwaukee & St. Paul
R. R. Co. vy; Armo, et al., 91 U.S. a Otto ) 489,
48 LAW OF DAMAGES. /
that the wrong was conceived ina spirit of mischief or crimin-
al indifference to civil obligation.’ And where the agent or
servant of a corporation has done an act ina spirit of mischief
or with a criminal indifference to civil obligation, the jury in
assessing damages against the corporation for the injury occa-
sioned by such may in addition to compensatory damages add
something more by way of punishment.‘ But before they can
assess exemplary damages, the evidence must show that the
agent or servant has been guilty of wilful misconduct or the
entire want of care which would raise the presumption of a
conscientious indifference to consequence‘
The Supreme Court of the State of Maine in commenting
on this question in the case of Godard v. Grand Trunk Rail-
way Company, say: It seems to us that there is no class of
cases where the doctrine of exemplary damages can be more
beneficially applied than to a Railroad Corporation in their
capacity of common carriers of passengers, and it might as
well not apply to them at all as to limit its application to car-
riers when the servant is directly or impliedly commanded by
the corporation to maltreat and in«ult passengers, or to cases
where such an act is directly or impliedly ratified, for no such
case will occur. A corporation is an inorganic being. It has
no mind but the mind of its servant; it has no voice but the
voice of its servant; and it has no: hands but the hands of its
servant. All its schemes of mischief as well as its.schemes
for public enterprise are conceiyed by human minds aud exe-
cuted by human hands.
All attempts therefore to distinguish between the guilt of
the servant and the guilt of the corporation or the malice of
the servant and the malice of the corporation is sheer non-
5 Day v. Woodard, 13 Howard, 371.
‘See authorities cited, also Milwaukee & St. Paul R. R. Co. v. Arms,
91 U. 8. 489.
EXEMPLARY DAMAGES. 49
sense, and only tends to confuse the mind and confound the
judgment. Neither guilt, malice nor suffering is -predicable of
this ideal existence called corporations. And yet under cover
of its name and authority there is in fact as much wickedness
and as much that is deserving of punishment as can be found
anywhere else. And since the ideal existence can neither be
hung, imprisoned, whipped, nor put in stocks—since in fact
no corrective influence can be brought to bear upon them
except that of pecuniary loss. It does seem to us that the
doctrine of exemplary damages is more beneficial in its ap-
plication to them than in its application to a natural person.
If those who are in the habit of thinking that it is a terrible
hardship to punish an innocent corporation for wickedness, of
its agent and servants will fora moment reflect upon' the ab-
surdity of their own thoughts, their anxiety will be cured.
Careful engineers can be selected who will not run their trains
into open draws; and careful baggage men can be secured who
will not handle and smash trunks and band-boxes as is now
the universal custom—and conductors and brakemen can be
had who will, not assault and insult passengers, and if the
courts will only let the verdict of upright and intelligent
juries alone and let the doctrine of exemplary damages have
its legitimate influence, we predict these great and growing
evils willbe much lessened if not entirely cured. There is
but one vulnerable point about these ideal existences called
corporations, and that is the pocket of the money power that
is concealed behind them, and if that is reached they will
wince. When it'is thoroughly understood that it is not pro-
fitable to employ careless and indifferent agents or reckless. and
insolent servants, better men will take their places and not be-
fore. It is our judgment therefore that actions against cor-
porations for willful and malicious acts of their agents and
servants in executing the order of the corporation should not
form exceptions to the rule allowing exemplary damages. On
the contrary we think that this is the very class of cases of
50 LAW OF DAMAGES.
all others where it will do the most good and where it is the
most needed.” 4 It will be seen from the reading of the above
decision that the Supreme Court of the State of Maine has
taken a wider range than the most of the courts of other
States. The Supreme Court of the State of Wisconsin in
commenting upon the question, says: “A principal is liable
in compensatory damages for injuries done by his servant act-
ing within the scope of his employment, and if the act is
such that the servant would be liable in punitory damages if
the action was against him, the principal is liable in dam-
ages of that character in case he authorizes the act or subse-
quently ratifies it but not otherwise.” °
54. The Opinion of the Court of Appeals of the State of New
York. The Court of Appeals in the State of New York in
commenting upon the liability of a master for the torts of his
servant, says: “For injury by negligence of a servant while
engaged in business of the master within the scope of his
employment, the latter is liable for compensatory damages, but
for such negligence however gross or culpable, he is not liable
to be punished in punitive damages unless he is also charged
with gross misconduct. Such misconduct authorized or
ratified, or that the master employed or retained the servant,
knowing that he was incompetent or from bad habits unfit for
the position he occupied. Something more than ordinary neg-
ligence is requisite. It must. be reckless and of a criminal
nature and clearly established. Corporations may increase
4 Goddard v. Grand Trunk Railway Co., 57 Maine 202.
A private corporation cannot be held liable for exemplary damages
‘for the negligence of its servant, merely, though if it knowingly employ
incompetent, drunken or reckless servants that may make it liable for
such damages. Illinois Central R. R. Co. v. Hummer, 72 Ill. 347.
5 Bass v. The G. & N. W. Railway Oo., 42 Wis.; Hagan v. Providence
R. BR. Co., 3 R. I. 88; Morfford y. Woodworth, 7 Ind. 83; Hamilton v. 3
Ausnee R. R. Co., 53 N. Y. 25.
~
HXEMPLARY DAMAGHS. 51
this liability as well as private persons.” The court after
commenting on the application of the rule to corporations says
that if a corporation employs a drunken servant, knowing of
his habits, they should be amenable to the severest rule of
damages, but that it was not aware of any principle which
permitted ‘a jury to award exemplary damages in a case
which did not come up to the standard or to graduate the
amount of such damages by their view of the propriety of the
conduct of the defendant unless such conduct was of the char-
acter already mentioned.”
55. The Pecuniary Condition of the Defendant. Not to be Con-
sidered. The question whether a jury in assessing exemplary
damages should be permitted to take into consideration the
pecuniary condition of the defendant and assess such damages
as he is in their opinion able to pay, has been discussed
recently in the supreme courts of several States and the con-
clusion reached is that the damages assessed to punish the
defendant for crime against society or the State should be
commensurated with the offense and not by his ability to pay.
But the jury may in assessing such damages take into consid-
eration the defendant’s rank and influence in order to arrive
at a conclusion as to the extent the injuries are increased
thereby.’ ‘ ’
56. When and for what Injuries Exemplary Damages will be
7 Cleghorn v. The New York Central & Hudson River Railroad, 56 N.
Y. 44,
Against carriers of passengers severe punitive damages will not be
allowed in the absence of any circumstance of malice, oppression, insult,
personal injury, damages to business, mental or physical: suffering, |
although something more than actual damages may be awarded against
common carriers by way of punishment for neglect of duty and pro-
tection to the public. Memphis, &c. R. R. Co. v. Green, 52 Miss. 779.
‘Smith v. Wunderlich, 70 Ill. 426; Jones v. Jones, 71 Ill. 562; Mc-.
Carthy v. Nirkern, 22 Minn. 9; Collins v. Mock, 31 Ark. 684.
52 LAW OF DAMAGES.
Allowed. We have already said that exemplary damages will
be allowed in cases based on fraud, malice, gross negligence or
oppression. We now propose to notice these cases in detail.
Commencing with fraud. It is not every case of fraud that
will authorize the assessment of exemplary damages. But on
the contrary in no case of fraud will such damages be allowed
unless it was committed under such circumstances as to imply
malice. There must be something more than mere fraud in
the transaction to warrant the finding of punative or exem-
plary damages.’ “If one knowingly or fraudulently misrep-
resents to his vendee the quantity or quality of a farm or the
condition or quality of personal property which he sells to
him whereby he is induced to purchase and is injured thereby
or knowingly and fraudulently misrepresents the pecuniary
standing of third person to one from whom such third person
is desirous of obtaining property on credit, whereby the per-
son to whom such representations are made is induced to give
such credit and is injured thereby, the well settled rule of
damages is one of compensation.” *
57. Malice. Next in the order we have named is malice.
‘The word malice in law means, in a general sense, willfulness.
The law collect the facts in the trial of a cause and judges of
the intention by the act. The act being itself wrong and un-
i Lane y. Wilcox, 55 Barber 615.
Fraud without damages gives no cause of action. Wiley v. Howard,
15 Ind. 169.
If the plaintiff therefore has purchased property through fraudulent
representation or concealment of material facts, cannot recover vin-
dictive damages when he fails to show he has sustained damages.
Barber v. Kellborn, 16 Wis. 489.
? Lane v. Wilcox, 55 Barber 615; McAvoy & Anthony v. Wright, 25
Ind. 22; Wheeler v. Randell, 48 Ill. 182; Ober v. Chapman, 15 Texas 400;
Nye v. Murriam, 35 Vt. 438; Platt v. Brown, 30 Conn. 336; Mulleson vy.
Herch, 17 Ind. 227; Wheeler v. Randall, 48 Il. 182.
EXEMPLARY DAMAGES. 53
lawful, an evil intent is inferred. That mischief which a man
does he is supposed to mean.” *® In other words the law will
‘in all cases of an unexplained injury to a third person pre-
sume malice or bad intention. The law presumes every man
to have acted with good motive until it is established by the
-evidence that he has committed a wrongful act. Then the
presumption shifts and he is presumed to have intended the
necessary consequence of his act.*
In order to recover exemplary damages it must be shown
that the act complained of was conceived in the spirit of mis-
chief or criminal indifference to civil obligation.‘
58. Gross Negligence. The next in the order we have
adopted is gross negligence or oppression. “Gross negligence is
the omission of that care which even the most inattentive
and thoughtless men take of their own concerns.” But to
authorize the assessment of exemplary damages, the negli-
gence must be so great as to amount to recklessness—that is to
a degree where a general, malicious or malignant purpose,
careless of consequences, might perhaps be presumed, although
no hostile purpose were entertained against the individual.
In other words the act must be wilful or of such a nature as to
show a reckless disregard for society or person and prop-
erty.®
3 Townsend on Slander and Libel, p. 87; Dexler v. Spear, 4 Missouri
115; Gaul and wife v. Fleming, 10 Ind. 253.
4 Philadelphia R. R. Co. v. Quigly, 21 Howe 202; Debble v. Morris, 26
Conn. 416; Dean v. Blackwell, 18 Ill., 336; Peoria Bridge Association v-
Looms, 20 Ill. 235; Overy v Hardin, 23 Ill. 403; Baltimore, &c. R. R. Co.
v. Blocher, 27 Md. 277; Bell v. Maunson, 68; Wallace v. The Atlantic R.
R., 36 N. H. 9; 9 Abb. Proct. 40, 18 1d. 169.
5 Pickett v. Crook, 20 Wis. 358; Louisville R. R. Co. v. Smith, 2 Du-
yall 556; Hull v. The Town of Richmond, 2 Woodruff & M. 337; The
Indianapolis, Bloomington & Western R. W. Co. v. McBowen, 46 Ind.
4
54 LAW OF DAMAGES.
59. Breach of a Contract to Marry an Exception to the Rule.
The general rule as to action upon contract is that the plaintiff
can only recover compensation for the.damages he has sus-
tained by the breach of the defendant, and exemplary or puni-
tory damages are not allowed. To this rule a breach of con-
tract of marriage is an exception, and so far as our research
has gone, is the only exception. As to the measure of dam-
ages, this action has always been classed with actions of torts
—as libel, slander, seduction, criminal conversation, &c. It is
the policy of the law to encourage matrimony, and society has
an interest in the contract of marriage, both before and after
they are consumnated. A man who enters into a contract of
marriage with improper motives and then ruthlessly and un-
justifiably breaks it off, does a wrong to the woman, and also
in a more remote sense to society, and he needs to be punished
in the interest of society as well as the man who commits a
tort under a circumstance showing a bad heart.
The rule of damages applicable ‘to ordinary contract
would be wholly inadequate. So much depends in each case
upon the circumstances surrounding it and upon the conduct,
standing and character of the parties. In all cases where vin-
dictive damages are allowed is upon the theory that the de-
fendant’s conduct has been such that he deserves to be punished,
and with a view of measuring out punishment to him as well
as compensation to the plaintiff, it is always competent to in-
quire into his motives and intentions to show that the act com-
plained of was done wantonly, maliciously or with a bad and
229; Banon v. Baltimore and Ohio R. R. Co., 24 Md. 108; Welch v. Du-
rand, 36 Conn. 182; Walker v. Erie R. R. Co., 63 Barber 260; Farrell v.
Warren, 51 Ill. 467; Green y. Craig, 47 Mo. 90; New Orleans, &c. R. R.
Co. v. Stateborn, 42 Miss. 607; Wardrobe v. Cal. Stage Co., 1 Col 118;
Wallace v. Mayorite, 2 Hilt. (N. Y.) 440; Hill v. Glanding; 42 Pa. stat.
493; Caldwell v. New Jersey Steamboat Co. 47 N. Y. 282; Coochrane v.
Miller, 13 Iowa 128; Bannon v. Baltimore R. R. Co., 24 Md. 108; Vicks-
burg et al R. R. Co. v. Patton, 31 Miss. 156. :
EXEMPLARY DAMAGES. 55
wicked heart, for the purpose of enhancing the damages.®
60. The Rule Does Not Apply in Case of an Injury by a
Domestic Animal. The rule allowing exemplary damages does
not apply in case of an injury to a person by a domestic ani-
mal, unless the defendant knew the animal to be vicious and
disposed to injure mankind and had been guilty of gross and
criminal negligence, evincing a wanton disregard of the safety
of others, amounting in law to malice, in controling said ani-
mal.®
61. Infants and Non Compos Mentis Not Liable for Exemplary
Damages. As has already been intimated the basis upon which -
the rule for the assessment of exemplary damages rests is an
evil intention. “Hence an infant or other person non compos
mentis cannot be held liable for exemplary damages, nor the
penalty provided by the statute for wilful and malicious acts
‘
€ Thorn v. Knapp, 42 N. Y. 474, 1 American Report 561; Southard v.
Rexford, 6 Cowen 254, Kiffin v. McConnell, 30 N. ¥. 285; Wells v"
Pagett, 8 Barber 323; Johnson v. Jenks 24 N. Y. 252; Burns v. Burk, 1
Lansing 268; Denstone v. Van Horn, Iowa 476; Davis v. Slagle 27 Mo
600; Simpson v. Black, 27 Wis. 206.
David S. Blackburn
Vv.
Mary Jane Mann, 85.1. 222.
Fidly v. McKinly, 21 Tl. 308.
2 Panon on Contract, 68.
3 ee 171.
Dryden v. Knowles, 33 Ind. 148.
The Supreme Court of the State of Ohio have decided that the filing
of a plea setting up the bad character of the plaintiff and failing ‘to have
it will not authorize exemplary damages. 12 Ohio stat. R. 312.
5 Pickett v. Cook, 20 Wis. 358. ;
Exemplary damages grow entirely out of the nature of the act of the
defendant for which the plaintiff recovers. They are given in enhance-
ment of ordinary damages on account of bad spirit and wrong intention
of the defendant manifested by the act, and are recoverable with ordin-
y
56 LAW OF DAMAGES.
beyond actual compensation, for they cannot be supposed to
act malicious.” *
62. The Nature of the Offense Should be Considered. In as-
sessing of exemplary damages the jury should consider the
nature of the offense; its probable effect on society ; the stand- —
ing of the parties, and measure the damages accordingly.
And if in the exercise of the discretion given by the law the
jury should go beyond reason in the assessment of punitive
damages, the court on proper application should grant a new
trial}
4
ary damages under the common allegation that the act declared for was
done to the damage of the plaintiff. Hoadly v. Watson, 45 Vt. 289.
3 Field on Damages, 85. Krom v. Schoonmaker, 3 (N. Y.) Barber 647.
5 Busket v. Lanato, 15 La. Arv. 337; Walker v. Smith, 1 Was c. c. 157.
When a servant was wrongfully dismissed, it was held that he might
recover exemplary damages. Moody v. Leverich, 4 Daly 404.
It is held by the Supreme Court of the United States that to author-
ize the infliction of exemplary damages for an injury to a passenger on
a railway train occasioned by a collision, the absence of care necessary
under the circumstances is not sufficient. There must have been to do
this some wilful misconduct, or.that entire want of care which would
raise a presumption of a conscious indifference to consequences. Mil-
waukee & St. Paul R. R. Co. vy. Arny et al 91 U.S. (1 Otto) 489.
Now, why all the unnecessary trouble and confusion and perplexity,
when the course of procedure should be plain, straight and unterrified.
The true rule, simple and just, is to keep the civil and the criminal pro-
cess and practice distinct and separate. Let the criminal law deal with
criminals and administer punishment for the legitimate purpose and
end of punishment, namely: the reformation of the offender and the
safety of the people. Let the individual whose rights are infringed and
who has suffered the injury go to the civil courts and there obtain the
fruits which he is not entitled to, and which belongs to others. Why
longer tolerate false doctrines which in its practical exemplification de-
prives a defendant of his constitutional right of indictment or complaint
on oath before being called into court, deprives him of his right to meet
the witness against him face to face, deprives him of the right of being
acquitted unless the proof of his offense is established beyond all rea-
sonable doubt, deprives him of his right of not being twice punished
for the same‘offense? Punitive damages destroy every constitutional
safeguard within their reach. And what is to be gained by this anni-
EXEMPLARY DAMAGES. 57
hilation and obliteration of fundamental law? The sole object in its
practical result seems to be to give a plaintiff something which he does
not claim in his declaration. If justice to the plaintiff requires the de-
struction of the constitution there would be some pretext for wishing
the constitution was destroyed. But only demolish the plainest guaran-
tees of that instrument, and explode the very foundation upon which
the constitutional guarantees are based for no other purpose than to per-
petrate false theories and develop unwholesome fruits. Undoubtedly
this precious doctrine has become so fixed in the law, to repeat the lan-
guage of Mr. Justice Campbell, of Michigan, “that it may be difficult to
get rid of it.” Butitis the business of courts to deal with difficulties,
and this heresy should be taken in hand without favor, firmly and fear-
lessly. It was once said: “If thy right eye offend thee, pluck it out,
and if thy right hand offend thee, cut it off.’ Wherefore, not reluct-
antly should we apply the knife to the deformity, concerning which
every true member of the sound and healthy may well exclaim, “I have
no need of thee.” ;
Fay v. Parker, 53 N. H., 342.
The radical difficulty in the position of the counsel; appears to be
that judgment for the criminal offense is for the offense against the pub-
lic; judgment for the tort is for the offense against the private sufferer;
that though punitory damages go in the sight of the public for example,
they do not go by way of public punishment, but by way of private dam-
ages for the act as a tort, and not asa crime to the private sufferer, and
not to the State. Though they are allowed beyond compensation of the
private sufferer they still go to him for himself as damages allowed by
the statute, considered as strictly punitory, the damages are for punish-
ment of the private tort, not of public crime. It is unfortunate that
damages should ever have been suffered to go beyond actual compensa-~
tion under a liberal. Brown v. Swinford, Supreme Court of Michigan,
vol. 7, Central Law Journal, 1879, p. 208.
3 Greenleaf evid. 841; Hill on Torts 181; Hamkin B 10. & P. 62 stat.
21; Hill on Torts 182; Conn. v. McLaughlin, 5 Allen 507.
CHAPTER IV. :
ASSAULT AND BATTERY.
ts DEFINITION. THe Derense. Tue ELEMENT oF Dam-
AGES. AmountT oF Damaces, AGGRAVATING C1RCUM-
stances. MiricgaTion of Damaces. THE RES GESTA
PROVOCATION MAY BE SHOWN. Tue Court 1g JUDGE WHAT
IS RES GESTA SELF DEFENSE. THE LAW PERMITS A MAN TO
ACT ON APPEARANCES. GREAT CAUTION TO BE USED. As-
SAULT WILL GENERALLY JUSTIFY A BLOW. COMPENSATION
AS A GENERALRULEIS THE DAMAGES. THE PLAINTIFF NEED
NOT FLEE. Wuar DAMAGES MAY BE PROVED UNDER GEN-
ERAL ALLEGATIONS. Elow DEFENDANT MAY DEFEAT THE
PLAINTIFF’S CLAIM. No DAMAGES CAN BE RECOVERED FOR
A LAWFUL AND PROPER ACT. SCHOOL TEACHERS, PARENT
AND CHILD. CORPORATIONS.
63. Definition of an Assault and Battery. An assault and
battery may be defined as the actual infliction of violence on
the person of another, or the touching of another in a rude in-
solent or angry manner by the defendant, or by a substance
put in motion by him.’ The striking of a horse on which a
man is riding, whereby he is thrown or taking hold of his
clothes, in an angry or insolent manner, or to drive against a
carriage in which another is sitting, isan assault and battery.’
2 Greenleaf evid. sec. 841; Hill on torts 181; Hampkin B., 1 C. & P. 62
stat. 21; Hill on torts 182; Conn. v. McLaughland, 5 Allen 507.
1 Dodwell v. Buford, 11 Mod. 24; United States v. Ortega, 4 Wash. 534
ASSAULT AND BATTERY. 59
If two men fight by agreement, the fighting is illegal and
the injured party may recover damages in an action against
the wrong doer.
64. The Defenses That May Be Set Up. The defenses that
may be set up have been enumerated in a brief and concise
manner by a commentator as follows:. “Where one who has
authority as a parent or master gives moderate correction to
his child, his scholar or his apprentice, so also on the principle
of self-defense. For if one strikes me first or even only as-
Hopper v. Reece, 7 Taunt. 698; 1 Hill on Torts 182; Kerland vy. The
State, 43 Ind. 146.
If an individual fires a pistol, either with malice, purpose or a total
disregard of human life, he and all acting with him are guilty of an as-
sault with intent to murder. Perry v. The People, 14 III. 496.
If one encourages a dog to bite another, be is guilty of an assault and
battery. Russell on crim. vol. 1, p. 751.
An assault-is an offer to strike, hurt or committ an act of violence on
the person of another without actually doing it. Johnson v. Thompkin,
1 Balt. 511-6.
“A battery is the actual infliction of violence on the person. Thus
the touching of the person in an angry, revengeful, rude or insolent
manner. Spitting upon the person, jostling him out of the way, push-
ing an other against him, throwing a squib or any missle or water upon
him, striking the horse he is riding, whereby he is thrown, taking hold
of his clothes in an angry or insolent manner to detain him, is a battery.
So to strike the skirts of his coat or cane in his hand, is a battery. For
any thing that is attached to his person partakes of its inviolability.”
2 Greenleaf, sect. 84; Kerland v. The State, 43 Ind. 146.
1 Adam v. Wagoner, 33 Ind. 531; 2 Greenleaf on evidence, sec. 85;
Baulter v. Clark, Butler N., p. 16; Stout v. Wen, 1 Hawkins, 420; Mat-
thew v Ollerton, comb. 218; Bell v. Honsley, 3 Jones, N. C. 131; Lagan
y. Austin, 1 Stuart 476; Dole v. Eskin. 37 N. H., 503; Exodus, 21 chap. 18
and 19 verses. ;
It is a settled doctrine that if one be attacked, he may lawfully defend
himself; using no more force than is ‘necessary for that purpose. He is
authorized to use sufficient force to repel the attack, but if he goes be-
yond this and uses more force than is necessary to repel the attack, he
becomes a trespasser himself and his assailant, though first in the
wrong, may maintain an action for-damages against him. Fisher v.
Bridges, 4 Black. 518; Filbeck v. Foster 14 Ind. 442; Dole v. Eskin, 35 N.
H. 503; Adams v. Wagoner, 33 Ind. 531.
60 LAW OF DAMAGES.
saults me, I may strike in my own defense, and if sued for it
may plead son assault demense or that it was the plaintiff’s
own original assault that occasioned it. So, likewise, in de-
fense of my goods or possession. If a man intends to deprive
me of them, I may justly lay my hands on him to prevent an
injury, and in case he persists with violence proceed to beat
him any.*
65. The Elements of Damages. The elements of damages in
cases of this kind are: 1st. “Loss of time and labor from the
date of the injury until the party recover therefor. 2. Dim-
inished capacity to work at the trade or the business of the
party injured. Bodily pain and mental anguish. 3. The ex-
pense of medical, surgical and other attendance and value of
clothing injured or destroyed.” °
8 Blackstone com. 120; 1 Hill on Torts 184; 2 Greenleaf on evid 155-
156; Gregory v. Hill, 8 T. R.- 297; Williams v. Jones, 2 Stark 10,149;
Green v. Batsam, 4C.& P. 308; Roe v. Wilson, 1 Bing 353, 8 J. B.
Moore, 362 S. C.; Weaver v. Bush, 8 T. R 78; Tulla v. Reed, 1 C. & P.
C.; Adams v. Freeman, 12 Johns 408; Hawk Pl. 1, chap. 31, sec. 49.
The mere taking hold of the coat, or laying the hand gently on the
person of another, if done in anger or in a rude and insolent manner, or
with a view of hostility, amounts not only to an assault but to a battery.
U.S. v. Ortega, 4 Wash. 534.
6 Field on the law of damages 471; 2 Greenleaf evid., stat. 267; Cox v.
Vanderbleed, 21 Ind. 164; Hendrixson v. Ringley, 21 Id. 379; Wiley v.
Keokuk, 6 Kan. 111; State v. Sherman, 5 Bush. (Ky.) 206; Smith v. Rail-
road Co. 23 Ohio st. 10; Sedgewick on damages 35-36; Flag v. R. R. Co.
43 Ill. 365; Fay v. Parker 53 N. H. 342; Daily Post v. McArthur, 16 Met.
447 Ruth Inst. B. 1, chap. 17, sec. 1; 102 Garrard, sec. 80; Harrison &
Swift, 13 Allen 144.
In an action for injury to the person, damages to the reputation can-
not be allowed. Kilper v. Hyer, 38 Ind. 499.
In an action to recover damages for an injury to the person of the
plaintiff, caused by the wrongful act or the omission of the defendant, the
jury in estimating the amount of recovery, may consider the suffering
and anxiety of mind of the plaintiff caused by such injury. Wright v.
Crumpton, 53 Ind. 337.
Evidence of previous threats made by the defendant in the presence
of the plaintiff, is admissable to increase the damages. 2 Hay 402.
ASSAULT AND BATTERY. 61°
66. The Rule for the Assessment of Damages. The general
rule for the assessment of damages is for the jury to take into
consideration every circumstance of the act which injuriously
affects the plaintiff, not only in his property, but in his per-
son, his peace of mind—in short his individual happiness.’
67. Aggravating Circumstances. The law is well settled
that if the defendant was actuated in making the attack by
malice, or perpetrated the wrong in a total disregard of the
law, and the plaintiff was not in the fault or in no way to
blame, the plaintiff may not only recover the pecuniary loss
sustained, but for his mental anxiety, public degredation and
wounded sensibility which an honorable man might be sup-
posed to feel from a violation of the sacredness of his person
for pain of feeling as well as to the body, and in addition ex-
emplary damages are sometimes allowed. *
68. Mitigating Circumstances. The defendant may show in
mitigating of damages that he in making the attack, acted in
the honest belief produced by the acts of the plaintiff that
he was in danger of receiving some bodily harm at the hands
of the plaintiff, which he could only repel by the use of force,
and that in making the assault, he only used such force as he
deemed sufficient to defend himself and no more.’
69. Time of Provocation, But before the defendant can give
evidence of provocation in mitigation of damages, he must
7 Taber v. Hutson. 5 Ind. 322; Cox v. Vanderkleed, 21 Ind; 164.
1 Wadsworthfv. Treat, 43 Me. 163; West v. Forest, 22 Mo. 344; Wilson
vy. Middleton, 2 Cal. 54; McNamer v. King, 7 Ill. 432; Jefferson v.
' Adams, 4 Harr. 321. _
Fay v. Parke, 53 N. Y. 342; Cox v. Vanderkleed, 21 Ind. 164,
* Key v. Dembin, 3 E. D., N. Y. 518.
62 LAW OF DAMAGES,
show that they were so recent and immediate as to influence
his conduct.*
70. The Plaintiff's Character Cannot be Attacked. The de-
fendant has in some cases been permitted to attack the plain-
tiff’s character and to show that he was a worthless, lazy vaga-
bond. But as the action is not brought to recover damages for
injury to character or reputation, such evidence should be ex-
cluded.‘ Both parties should be confined on the trial to the
principle transaction complained of and to its attendant cir-
cumstances and natural results, for they are the only questions
at issue.®
71. The Defendant's Good Nature Cannot be Shown in Miti-
gation of Damages. The defendant cannot show in mitigation
of damages that he is and always has been a peacable, good
natured man, nor can such evidence be introduced for the pur-
pose of rebutting the presumption of malice.’ Nor will he be
permitted to show that statements made by the plaintiff at
* Lee v. Wosley, 19 Johns N. Y. 319; Jackaway v. Dula, 7 Yerg, Tenn.
82; Fullerton v. Warrick, 3 Black. 219; Matthew v. Terry, 10 Conn. 455;
Greermyer v. Morris, 2 Root (Conn.) 252; Ellsworth v. Thompson, 13
Wend. (N. Y.) 658; Cox v. Whitney, 9 Me. 531; Barry v. Ingles, 2 Hayne,
102.
A man may repel force by force in defense of -hi person or property
against an effort to commit felon on either common. Smith vy. Ellinger.
1 Burns, (Pa.) 452.
4 Ward v. State, 29 Ala. 53.
5 Butler v. Gould, 34 Ind. 552; 2 Greenleaf evid. stat. 268.
The amount of damages in case of an assault and battery is not fixed
by law, but is left to the discretion of a jury, and they should look to the
nature and extent of the injury and the circumstances under which they
were inflicted, and then say what is just and proper under all the cir-
cumstances. 26 Ind. 168.
The defendant cannot prove in mitigation of damages that he has
been indicted, tried and convicted and fined by the State. Philips v.
Kelly, 27 Ala. 628,
ASSAULT AND BATTERY. 63
the time of the assault and connected with it were known by
the plaintiff to be false.®
72. The Res gesta may be Shown. The law is well settled
that all the circumstances which immediately accompanied
the transaction will be considered a part of the resgesta and
may be given in evidence, and are sometimes material in ar-
riving at the amount of damages the plaintiff ought to re-
cover."
73. The Defendaut may show Provocation in Mitigation of Dam-
ages. The defendant may show in mitigation of damages that
he was provoked to make the assault and battery by the in-
sulting language of the plaintiff. But before he will be per-
mitted to introduce such evidence, he must show that the pro-
vocation was so recent as to raise a reasonable presumption
that he was actuated by the heat of passion caused by the use
Thrall y. Knapp, 17 Id. 468. -
® Butt v. Gould, 34 Ind. 552.
The difficulty between the parties grew out of a dispute about some
house rent which Butt claimed was due, and which Gould insisted he
had paid. Each party roughly impeached the veracity of the other, and
immediately following this the defendant struck and beat the plaintiff.
The defendant then proposed to show what he said about the rent, was
then it was rejected and not held right. Butts v. Gould, 34 Ind. 55.
72 Greenleaf evid. stat. 267.
In a civil action for damages for an assault and battery, evidence that
the plaintiff had said that he did not think the defendant always in his
right mind, there being no evidence that it was communicated to the de-
fendant, and no pretence that he ever was insane will not be admissable.
Gaither v. Blower, 11 Md.536. |
A person guilty of a wilful assault and battery cannot show that from
the intemperate habit of the other party the injury was more aggravated
than it would have been upon a person of temperate habits. 11 Cush.
360.
64 LAW OF DAMAGES. ,
of such language.’ Whatever occurred during and immediate-
ly before and after the assault, being so closely connected
with it as to form a part of it can be given in evidence as a
part of the res gesta.
75. The Court is to Judge if the Act is a part of the Res Gesta.
The question as to whether the language or the act proposed
to be proved were a part of the res gesta or not must be deter-
mined by the court when the proof of such facts is offered.
If the records or acts were just recently previous to the as-
sault or were a part of a series of insults and irritating provo-
cations, they should go to the jury in order to show the true
character of the whole transaction.*
76. The Law Recognizes the Passions of the Human Mind.
The law recognizes and respects the passions of the human
mind, and looks at man when his conduct is under investiga-
tions as an infirm creature governed and eontrolled to a cer-
tain extent by passion and prejudice, and inflicts npon him
just such punishment as his conduct deserves. Therefore
while it is held as a general rule that words spoken long be-
fore the assault occurred cannot be admitted in evidence to
show provocatiou and to mitigate the damages. Yet where
such acts or words are a part of a series of provocation fre-
quently repeated and continued down to the time of the as-
’ Thall v. Knapp, 17 Id. 468.
4 Ireland v. Eliot, 5 Iowa 478.
5 Shirly v. Billings, 8 Rush (Ky.) 147.
On the trial of a civil action for assault and battery, it is competent
for the purpose of mitigating vindictive damages to show that the de-
fendant has been convicted and punished at the suit of the State for the
same transaction. Smithwick v. Ward, 7 Jones (N. C.) L. 64.
ASSAULT AND BATTERY, 65
sault, they may be admitted as evidence in mitigation of dam-
ages."
76. The Degree of Force to be Used will Depend on Circwm-
stances. The degree of force that one may use in repelling an
attack will depend upon the surrounding circumstances. If
the defendant knows the plaintiff to be a large man, much
stronger than himself, and believes that he intends to do him
great bodily harm, the law will permit him to use greater
force than if his assailant was a small, infirm man.
77. The Law Permits a Man to Act on Appearances. The law
recognizes the fact that man is fallible, and therefore permits
him to act on appearances, and when he acts on appearances,
the question should be submitted to the jury as to whether the
defendant had reason to believe and did believe that he was
in danger of receiving a severe injury from the plaintiff, and
used just such force as he under the circumstances thought was
necessary to repel the attack.®
/
78. Great caution should be used by the Defendant in making
his defense less he uses more force than is necessary. If, as has already
"Stella v. Nellies; 60 Barber (N. Y. ) 525, 42 Howe Proct. 163.
Field on the law of damages, 476. Dolan v. Fagan, 63 Barber (N.*Y.)
73.
Evidence may be given on mitigation of damages without having filed
answer on the execution of the writ of inquiry in an action of assaalt and
battery and false imprisonment. Hays v. Berrymore, 6 Bosue (N. Y.)
679.
5 Field on damages, sect. 607.
A man may repel force by force in the defense of his person or prop-
erty against an effort to commit a known felony on either. In such case
the defendant should be excused if he acted upon reasonable appear-
ances, though it turned out that they were false, and that there was no
_ actual danger. Commonwealth v. Ellinger, 1 Bund. (Pa.) 352.
8 People v. Shorter, 4 Barber 460; Loge vy. The Commonwealth; 2
Wright; Pa. 265,
66 LAW OF DAMAGES.
been said, the defendant in repelling the attack goes beyond
what was apparently necessary for self-defense, it seems that
the excess may be given in evidence against him.’ The rule
is that when the defendant pleads justification, he must estab-
lish by evidence that no more force was employed than the
exigency reasonably demanded. Whenever justification is
founded on a defense of personal or real property in ordinary
cases it is sufficient for the defendant to show that he was in
lawful possession of the same, and that he used no more force
thar was necessary to protect his property.”
The question as to the degree of force that was necessary
to be used must be submitted to-and determined by the jury
under the instruction of the court.!
79. An Assault will generally justify a Blow. As a general
rule, an assault will justify a blow, but if the defendant’s
beating is excessive he will be held responsible in damages.
In order for the defendant to defeat the plaintiff’s claim for
damages on account of misconduct of plaintiff not amounting
to an assault, he must show that he was wholly free from fault.
No words of provocation will justify an assault and battery,
although they may constitute a ground for the reduction of
damages.’
”
6 2 Greenleaf evid., Sect. 95, p. 77.
Curtis v. Casson, 2.N. H. 539; Haner v. Elder, 15 Mass. 347; Bennett
v. Appleton, 25 Wend. 539.
7 2 Greenleaf evid., Sect. 98, p. 79.
_ A right to the possession of real estate will not justify an assault and
battery to obtain the same.
Possession in fact justifies the use of violence if necessrry to defend it.
Parson v. Bronson, 15 Barber, 590.
3 Greenleaf evid. Sect. 95, 1; Hazel v. Clark; Commonwealth v Ellinger
1, Barns 352; Mons v. Platt, 32 Com. 75, 3; Hassing 22, 2; Phillips v.
Kelly, 29 Ala. 528,
’ Cushman v. Ryon, 1 Story 21; Keys v. Delwin, E. D. Smith, 518;
Ireland v. Elliott, 5 Clark (Iowa) 478; Suggs vs. Anderson, 12 Geor. 461.
ASSAULT AND BATTERY. 67
80. Compensation as a general rule the measure of damages.
As a general rule in this class of cases where no element
of outrage or malice enters into the conduct of the defend-
ant, the plaintiff can only recover compensatory damages, or
such as will fully compensate him for the injury he
has sustained, including loss of time, medical and other “ex-
penses, physical pain and mental anguish, as they are the
natural consequence of the plaintiff’s injury” of which he
complains.‘
_ 81. The righttorecover exemplary damages questioned. And where
the element of malice, etc., enter intothe commission of the offense
the right to recover more than compensatory, damages is now
questioned. Andit is thought that the weight of the most re-
cent authorities is against allowing exemplary damages where
the assault and battery for which damages is claimed is pun-
ishable by indictment and fine.
82. Exemplary damages allowed in certain cases. But the
weight of authority holds that where the offense for which
damages are claimed, is not made punishable by the laws of
the State, and the elements of malice, fraud and oppression enter
into and form a part of the wrongful act, that the jury in assess-
The amount of damages is not fixed by law, but is left to the sound dis-
cretion of the jury; they should look to the nature and extent of the
injury inflicted, the circumstances under which it was inflicted, and.
then say what is just and proper under all the circumstances.
Little v. Johnson, 26 Ind. 168.
4 Field on the law of damages, 432; Peoria Bridge Ass. v. Looms, 20
Tl. 235; Hunt v. Hoyte, Ind. 544. The inhabitants of Elsworth 32, Md. °
271; More v. Auburn & Troy R. R. Co., 10 Barber, 621; Ranson v. N. Y.
& Erie R. R. Co., 15 N. Y. 415; Keys v. Delwin 3 E. D. 8. (N. Y.) 518;
West v. Forest 22 Md. 344; Bannon v. Balt. & R. R. Co. 24 Md. 390;
Fanchila v. Cal. Stage Co. 13 Cal. 599; Wells, Fargo & Company 5 New.
224; Penn. Canal Co. v. Graham, 63 Pa. St. 390. »
5 See exemplary damages.
‘
68 LAW OF DAMAGES.
ing damages, may blend together the rights of the injured
party and the interest of the community, and assess damages
not only to compensate the plaintiff for the injury he has sus-
tained, but to punish the defendant.*
83. The plaintiff need not flee. The law does not require one
to flee from an assailant before he willbe entitled to recover
damages for an assault and battery. If he uses ordinary care
to prevent injury, and injury ensues from the wrongful act of
the defendant the plaintiff may recover.
84. The plaintiff’ may under the general allegation of the complaint
recover such damages as naturally and necessarily arise from the injury.
In an action to recover damages for an assault and battery
* Hendricks v. Kingsberry, 21 Iowa 379. Exemplary damages grow
entirely out of the nature of the act of the defendant, for which the
plaintiff recovers. They are given to enhance ordinary damages on ac-
count of bad spirit and wrong intention of the defendant manifested by
the act, and are recoverable with ordinary damages under the common
allegation that the act declared for, was done to the damage of the plain-
tiff, Hoodley v. Watson, 45 Vt. 892.
Smith v. Holcomb, 99 Mass. 255; Holyorke v. G. J. R. R. Co. 48 N. H-
541; Stock v. Hersy, 4 Gill. (Md.) 406; Smith v. Veesly 30 Gro. 241; Cox
vy. Vanderleed 21, Ind. 164; Gould v. Christian 1 B. & H.507; McGrew v.
Stone 53 Pa. St. 436; Sharpe v. Powell, 7 C. & T. 250.
6 Heady v. Wood, 6 Ind. 82.
When a man is assaulted under circumstances that are of such a char-
acter as would lead a reasonable man to believe that the assault is made
with a design to take his life, or to inflict extreme bodily injury, he will
be justified in both civil and criminal law, if he kills or attempts to kill
his assailant. And the question whether the belief was reasonable or
not, must be passed upon by a jury, but a person does not act in such
case at the peril of making that guilt, if appearance prove false, which
would be innocence if they proved true. Morris v. Platt, 32 Conn. 755
Commonwealth v. Ellinger, 1 Burs. (Pa.) 352; Gallagher v. State, 3,
Minn. 270. Asa general rule, the law will not justify a man who: repels a
plow with a fist by stabbing his assailant, whether or not such stabbing
amounts to self-defense, depends upon the nature and violence of the
assault thus repelled. Floyd v. The State, 36, Gv 91. When a person
in lawful self-defense fires a pistol at an assailant and misses him, and
wounds an innocent bystander, he is not liable fur the injury if not
guilty of negligence. _ Morris v. Platt 32 Conn. 75,
ASSAULT AND BATTERY. 69
where the petition is general, containing no allegation of any
special damages, the plaintiff may on the trial give evidence
of any damages naturally and necessarily resulting from the
act complained of, where the damage is consequential it must
be specially set forth in the petition or complaint.’
85. How the Defendant may Defeat the Plaintiffs Claim for
Damages. The defendant may defeat the plaintif’s claim for
damages by showing—
{
1. That he never committed the assault and battery com-
plained of.
\
2. That the injury was done while in the detense of him-
self or some member of his family or his property. But to jus-
tify an assault and battery bya man in defense of himself, some
member of his family or his property, the danger should be such
as to induce one exercising reasonable and proper judgment to
interfere to prevent the consummation of the injury.? In de-
fense of the possession of property, the plaintiff is not justified
in the use of force until he has requested the trespasser to de-
sist, except in cases of violence or taking of the property by a
trespasser or the like, for otherwise the party interfering to pre-
vent wrong will himself be guilty of an assault.
|
Oleay v. Roman 81 Mo. 117. It is not necessary in an action for a
‘ simple assault and battery for the plaintiff to allege in terms that it was
willful or malicious to entitle him to maintain his action. Andrews v.
Stone, 10 Minn. 72. The plaintiff in an action for an assault and bat-
tery need not set out in his declartion such damages, as the law will pre-
sume to see the necessary or usual consequences of the injury received,
and for such damages he may recover, even though they accrued after
the commencement of the suit. Birchard v. Booth, 4 Wis. 67
2 Greenleaf evid. Sec. 95; Hill v. Rodgers 2 Iowa 67; Field on the law
of dam. Sec. 616. In the case of Paton vs. Boyer the Supreme Court of
the State of Illinois: “This is an action for trespass for an assault and
battery and verdict for $450 damages. The jury found this special ver-
dict: That-from the evidence the blow complained of was struck by the
70 LAW OF DAMAGES.
3. That the injury complained of was unintentional on
his part, resulting from a lawful act, and that in the exercise
of his lawful right that neither negligence or folly was im-
puted to him.
defendant without malice and under circumstances which would have
lead a reasonable man to believe it was necessary to his proper self de—
fense. This conduct was found, under the instructions of the court,
that the jury in addition to the general verdict find a special verdict em-
bracing this proposition or its converse. The testimony shows that the
trespass by the defendant against an unoffending party, against one that
gave no cause or provocation of any kind. The defendant asked this,
which was refused: ‘The defendant cannot be found guilty in an ac-
tion of this kind, unless in inflicting the injury complained of he has
been guilty of some wrong, evil intent or want of care, and if you find
from the evidence that he struck the blow without fault you will find for
the defendant.”’?’ On coming in of the verdict the defendant moved for
a verdict on the special finding, which the court denied. This is the
‘ first point made by the appellant. He insists that judgment should
have been rendered for the defendant upon the special verdict, as that
ignores malice and unlawful intent, and finds that the act was done un-
der circumstances which would have led » reasonable man to believe
that it was necessary to his proper self defense. Appellant’s theory is
that he mistook the plaintiff for his brother, with whom he was in con-
flict and who had felled him to the floor by violence. The court for the
plaintiff instructed the jury that it was no defense, so far as actual
damages are concerned, that the defendant had been violently assaulted
by other than the plaintiff, or wasthen being assaulted by such other per-
son, or that he may have honestly believed that he was striking Peter
Boyer when he struck the plaintiff, or that he may have honestly be-
lieved it was necessary for his self defense to assault the plaintiff. If
the jury find from the evidence that the plaintiff was not a party to such
assault upon the defendant, such evidence of mistake of fact or good in-
tention on the part of the defendant can only be considered in this case
by the jury as a defense against inflicting by the jury of vindictive dam-
ages, and not as a defense against such actual damage as the evidence
may show the plaintiff has suffered from such assault or as natural re-.
sulting from such. These instructions involve the merit of the contro-
versy. Appellant relies in support of his theory upon Morris v. Platt,
32 Conn. 75, and Brown v Kendall, 6 Cush. 292. These cases are fully
discussed and sustain appellant. The facts in both cases are similar to
those in this case, and were actions of assault and battery. The princi-
ple is announced in those cases that a person is not liable for an uninten-
tional injury resulting from a lawful act where neither negligence nor folly is
imputed to him who does the act, and that the burthen of proving the
ASSAULT AND BATTERY. 71.
86. The defendant is not liable on a lawful and proper act.—The
law is well settled that if the defendant at the time the injury
occurred was doing a lawful and proper act which he might do
by the use of lawful and safe means and while he was engaged
in the act using all proper precaution necessary to the exi-
gence of the case to avoid hurt to others the plaintiff is injured,
the defendant will not be liable.”
87. Chastisement of a Seaman. The law is pretty well set-
tled that the master or commander of a vessel may, under cer-
tain circumstances, chastise his seamen and he will not be lia~
ble to an action for an assault and battery for such chastise-
ment where he acts under a sincere conviction that it was
necessary to enforce discipline or compel obedience to orders
and not from passion or revenge.’ And if the master, acting
in the exercise of a sound discretion and believing from the
circumstances that there is imminent danger from mutiny or
from honest motives, makes use of dangerous or deadly
weapons to reduce a seaman actually in mutiny to obedience,
he will not be liable to an action or prosecution therefor, al-
though it may appear that less severe measures might have
answered.*
negligence or folly when the act is lawful is upon the plaintiff. * * *
The rule is well established that in an action of an assault and battery
the plaintiff must be prepared with evidence to show either that the in-
tention was unlawful or that the defendant was in the fault.
? Greenleaf evid. Sec. 85.”’
67 Ill. 132, see also authorities above cited. |
° Parrett v. Wells, Fargo & Co., 15 Wall 524; Dixon v. Bell, 5 Me. and
Sec. 1198.
Brown vy. Collins, 53 N. H. 442; Bissel v. Baker, 19 Ark. 308.
8 Dinsman v. Wilks, 12 Hom. 390; Morris v. Cornell, Sprague 62;
Sheridan y. Fusleur, 1 Blatchf. and H. 423; U.S. v. Freeman, 4 Mass.
505 and 511.
4 Roberts v. Eldridge,. Sprague 54; U.S. v. Colley, id. 119. U.S. v.
Lent, id. 311.
But where personal violence is inflicted not excessively but wantonly,
92 LAW OF DAMAGES.
88. School Teachers may Administer Reasonable Punishment.
The law permits a school teacher to administer to his pupils for
the purpose of maintaining order and good government in his
school, moderate correction. So long as the power to punish
corporally in schools is recognized and upheld by the law,
courts should put it under wholesome restrictions. The teacher
should understand that whenever correction is administered in
anger or insolence or in any other manner than in moderation
and kindness, accompanied with that affection and moral
suasion so eminently due from one placed by the law in loco
parentis—in the sacred relation of parent—he will be deemed
guilty of an assault and battery, the more aggravated and
wanton in proportion to the tender years and the dependent
position of the pupil.
89. AParent may Injlict Moderate Correction. The law is
well settled that a parent may inflict moderate correction upon
his child such as is reasonable under the circumstances. If he
goes beyond this he is indictable and responsible in damages
for an assault and battery.‘ The question as to what is mod-
erate correction the law has not attempted to define. And we
think that, perhaps, it is well that no definite rule can be laid
down on this point, for after all “that might be said the in-
stinct of court and jury, as expressed in each particular case,
will usually be found to be the best guide.’* ,
and without provocation or cause, or where there was a provocation or
cause, but the punishment was cruel or excessive. Forbes v. Parson,
Craleb 283, 12 Han. 390.
® Cooper v. McJunkin, 4 Ind. 290; 14 Johns R. 1191 ; Hillon Torts, 183 ;
Hathaway v. Rice, 19 Vt. 182.
° 2 Greenleaf, Sec. 971; Sanders’ Plea and Evidence 107; Matthews v.
Terry, 10 Conn. 455; 1 Hawkins P. C. C. 60; 23 Watson v. Christy. 2 B,
and P. 224; Sampson v. Smith, 15 Mass. 365; Thorn v. White, 1 Pet.
Adx. 173.
§ 1 Bishops Crim. Law, 8. 880.
AssauLT AND Battery. a3
91. Corporation Liable for Assault and Battery. Where a rail-
road conductor uses unwarrantable violence in attempting to
collect fare, the company will be guilty of an assault and bat-
tery and responsible to the injured party in damages.’
? Ramsden v. Boston & Albany R. R. Co., 104 Mass. 117; Moore v.
Fitchburgh R. Co., 4 Gray 465; Huett v. Swift, 3 Allen 420; Holmes v.
Wakefield, 12 Allen 580; O’Brien v. Boston & Worcester R.R Co, 15
Gray 20; Philadelphia, Wilmington & Baltimore R. R. Co. v. Quigley,
21 Howard (U. S.) 202; A. & G. W. R. R. Co. v. Dunn, 19 Ohio st. 162.
!
. CHAPTER V.
CRIMINAL CONVERSATION AND SEDUCTION.
AN ACTION AT Commen LAW LIES IN FAVOR OF A HusBAND
FOR CRIMINAL CONVERSATION AND SEDUCTION OF HIS WIFE.
THE PLAINTIFF MUST PROVE A MARRIAGE. EvIDENCE To
SHOW MARRIAGE. THE ACT OF ADULTERY—HOW PROVEN,
TIME AND PLACE NEED NOT BE PROVED AS ALLEGED. THE
PLAINTIFF MAY SHOW THE STATE OF DOMESTIC FEELING THAT
EXISTED BETWEEN HIMSELF AND WIFE BEFORE THE ADUL-
TEROUS INTERCOURSE. LETTERS OF THE WIFE. WHEN
THEY CAN BEINTRODUCED AS EVIDENCE, THE WIFE’S CHAR-
ACTER BEFORE SEDUCTION PRESUMED TO BE GOOD. PLAIN-
TIFF CANNOT RESENT DIRECT PROO! OF ACTS OF ADULTERY
BY GOOD REPUTATION. THE WIFE’S CHARACTER AND REPU-
TATION IN ISSUE. THE OPINION OF WITNESS AS TO WHETH-
ER PLAINTIFF AND HIS WIFE LIVED HAPPILY TOGETHER CAN-
NOT BE RECEIVED. THE FACT THAT THE PLAINTIFF CON-
TINUED TO LIVE WITH HIS WIFE NO BAR TO THE ACTION.
MITIGATING CIRCUMSTANCES MAY BE SHOWN BY THE DE-
FENDANT. THE DAMAGES, ELEMENTS OF DAMAGES. SE-
DUCTION. ACTION FOR DAMAGES EMBRACES EVERY LOSS AND
INJURY. AGGRAVATION OF DAMAGES MAY BE SHOWN.
92. Action at Common Law. An action at common law lies
in favor of a husband for criminal conversation and seduction
of his wife. It is based on the loss of comfort, fellowship and
' assistance of his wife.?
2 1 Saunders, P. and E. P. 395; 1 Chitty Pleadings 642.
The usual form of the complaint is as follows: John Smith com-
plains of Henry Adams, and says that heretofore, to-wit, the defendant
8
CRIMINAL CONVERSATION AND SEDUCTION. "5
93. The Plaintiff Must Prove an Actual Marriage. The plain-
tiff in order to recover, must prove an actual marriage. The
law raises no presumptions of marriage from proof. of cohabita-
tion, recognition, reputation or other circumstances. The
authorities are not uniform as to whether the defendant’s ad-
missions of the marriage of the plaintiff and his wife may be
given in evidence against him, but there is no good reason why
such declaration should not be received as a link in the chain
of evidence, though it may not be sufficient to establish the
fact. And they are admissable for the purpose of showing that
the defendant committed the offense with a full knowledge of
the relations of the parties.® But it may now be considered
pretty generally settled that if the defendant has seriously ad-
mitted the marriage it will be sufficient proof of the fact.
Thus when the defendant deliberately declared that the female
was married to the plaintiff, and that with full knowledge of
that fact he had seduced and debauched her, this was held
sufficient.®
combining and wrongfully intending to injure the plaintiff and deprive
him of the comfort, society, aid and assistance of Nancy Smith, the wife
of this plaintiff, and to alienate and destroy her affection for him, here-
tofore, to-wit, on the 19th day of July, 1879, and on divers other days
thereafter and before the commencement of this suit wrongfully and
wickedly debauched and carnally knew the said Nancy Smith, she being
then and ever since has been the wife of the plaintiff, by means whereof
the affection of the said Nancy Smith for the plaintiff was wholly alien-
ated and destroyed. And by reason of the premises the plaintiff has
wholly lost the comfort, society and assistance of his said wife, which all
the time aforesaid he otherwise might and ought to have had, tothe
damage of the plaintiff of ten thousand dollars, for which he demands
judgment. A. B., Attorney for Plaintiff.
4 2 Greenleaf on evid. s. 49; Weedon vs. Limberell 5 T. R. 357; Cam-
bers vs. Caulfield, 6 East 244; Winter v. Henn, 4 C and P. 494; Bastelet
v. Henn, Peaks case 7; Welton v. Webster, 7 C. and P. 494; Haugh v.
Watson, 7 M. and G, 644; Field on damages, 117 S. 103; 1 Greenleaf evid.
S. 49; Cook y. The State of Georgia, 11 Georgia 53; Riggs v. Curgeon, 2
Wels 399.
51 Greenleaf, Sect. 49.
6 Forney v. Hallock 8 S. and R. 159.
46 LAw oF DAMAGES.
94. If the Plaintiff can show that the Marriage was in Accordance
with the Law of the State it will be Sufficient. As almost every State
in the Union has its own laws governing marriage contracts
and the solemnizing of marriages, it will be sufficient to prove
that the marriage was in accordance with the law of the coun-
try, state or territory where it took place." There must be sat-
isfactory proof of the identity of the parties.’
95. How the Acts of Adultery may be Proved. The plaintiff
must prove the fact of adultery, but he is not required to prove
it by eye-witnesses. It may be established by circumstantial
evidence alone. Lord Stowell, in commenting upon the
amount and kind of evidence required in such cases, said:
“Tt isa fundamental rule that it is not necessary to prove the
direct fact of adultery, because, if it were otherwise, there is
not one case in a hundred in which the proof would be attain-
able. It is very rarely, indeed, that the parties are surprised
in the direct act of adultery. In every case almost the fact is
inferred from circumstances that lead to its fair inference asa
necessary conclusion, and unless this were the case, and unless
this were so held, no protection whatever could be given to the
marital rights. What are the circumstances which lead to
such conclusion cannot be laid down universally, because they
may be infinitely diversified by the situation and character of
the parties, by the state of general manner and by many other
incidental circumstances apparently slight and delicate in
themselves, but which may have most important bearing in
7 Bulls, N. P. 28; Catherwood vy. Carlton, 13 M. and W. 261; Nixon v.
Brown, 4 Block 157.
12 Greenleaf on evid., Sect. 50. In a suit for criminal connection,
a marriage license issued in Tennessee, with certificate indorsed
thereon by a Justice of the Peace that he had solemnized the marriage,
the official character of the office granting the license, and also that the
Justice of the Peace being certified to by the clerk, the keeper of the
record, under his official seal and the presiding justice having attached
his certificate of authority, was held properly admitted. 1Scam. Ill. 513.
CRIMINAL CONVERSATION AND SEDUCTION. 77
decisions upon the particular case. The only general rule that
can be laid down upon the subject is that the circumstances
must be such as would lead the guarded discretion of a reagon-
able and just man to the conclusion, for it is not to lead a rash
and intemperate judgment moving upon appearances that are
equally capable of twointerpretations—neither is it to be a
matter of artificial reasoning, judging. upon such things dif-
ferently from what would strike a careful and cautious con-
sideration of a discreet man. The facts are not of a technical
nature; they are facts determinable upon common ground of
reason, and courts of justice would wonder very much from
their proper office of giving’protection to the rights of man-
kind if they let themselves loose to subleties and remote and
artificial reasoning upon the subjects. Upon such subjects the
rational and the legal interpretation must be the same.’
‘
The rule may be stated in a much briefer way, and yet with
as much clearness, force and precision by averring that the plain-
tiffmust present tothe court or jury trying the cause such proxi-
mate circumstances as to convince his or their judgement that
the defendant committed the crime.” Thus it has been held
that general cohabitation excludes the necessity of proof of
particular facts of adultery.’
3 Lowden v. Lowden, 2 Hogg Conn. R. 23; Dunham vy. Dunham, 6
Law Reporter 14. .
2 Williams v. Williams, 1 Hogg. con. R. 299; Dunham v. Dunham, 6
Law Rept. 141.
5 2 Greeleaf evid., Sect. 41; Codagon v. Codagon, 2 Hogg. R. 4; Bowers
admt.,-v- Vanwinkle, 41 Ind. 432.
The consorting with a prostitute by a married m.n raises a presump-
tion of adultery, unless explained and rebutted by the character of the
man, and when character is relied upon asa defense and fails in that
respect the presumption is increased. Civici v. Civici, 26 Eng. L, and
E. R. 604; Astty v. Astty, 1 Hogg. Eed, R. 719,
78 LAW OF DAMAGES.
96. Time and Place need not be Proved as Alleged. Ordinarily
it is not necessary to prove the act to have been committed
at any particular place or time. It will be sufficient if the
circumstances are such as tolead the court or jury, traveling
with every necessary caution, to the conclusion that the de-
fendant committed the act inside of the statute of limitation.
i
’
97. Anterior Acts of Adultery may be Shown. And where the
plaintiff alleges in his complaint that the criminal commerce
took place at a specified time after he has introduced proof of
improper freedom within the specified period, he may then intro-
duce, proof of acts anterior to the time alleged in his complaint
as explanatory of the acts of indecent familiarity within the
time alleged.’
98. The Plaintiff may Show the State of Domestic Happiness to
which he and his Wife Lived in Aggravation of Damages. The plain-
tiff may show in aggravation of damages the state of domestic
happiness in which he and his wife had previously lived and
the marriage settlement or othcr provision, if any, for the
children of the marriage, the relation, whether of friendship or
‘blood, confidence, gratitude, hospitality, and the like, which
subsisted between him and the defendant.' And the condition
, Gardner v. Meaderia, 2 yeats Pa. 466; 2 Greenleaf evid. 47; Duke of
Norfolk v. Germania, 12 Howells st. R. Tr. 929,945; 2 Greenleaf evid.,
Sect. 47; Sherwood v. Titman, 55 Pa. st. 77; Gonaway vy. Nichols, 34
Iowa 533.
In an action of criminal conversation, an improper intimacy between
the defendant and plaintifi’s wife having been shown for over a year
prior to a separation between the plaintiff and his wife, evidence of such
intimacy continued after the separation is admissible as acts serving to
interpret their previous conduct. Sherwood v. Titman, 55 Pa. st. R. 77.
1 2 Greenleaf on evid., Sect. 55; Duke of Norfolk v. Bedding, 6 C. and
P. 589.
CRIMINAL CONVERSATION AND SEDUCTION. 79
in life and the pecuniary circumstances of the respective par-
ties.’
99. The Plaintiff may Introduce Evidence Showing the Affection
Existing Between Him and his Wife Before the Adulterous Intercourse.
The plaintiff may, for the purpose of proving the state of affec-
tion and feeling that existed between him and his wife prior
to the adulterous intercourse, show their previous conversation,
deportment and letters.» And the language and letters of the
wife written before the alleged adultery to other persons he
can introduce for the same purpose.*
100. Letters of the Wife to a Friend in the Defendant’s Hand-
Write may be Introduced to Show Intimacy. For the purpose of
showing the intimacy that existed between the defendant and
2-Considering as a civil injury (and surely there can be none greater)
the law gives a satisfaction to the husband for it by action of trespass
ot et armis against the adulterer, where the damages recovered are
usually very large and exemplary. But these are properly increased
and diminished by circumstances, as the rank and fortune of the plain-
tiff and defendant, and the relation or connection between them, the
seduction or otherwise of the wife, founded on her previous behavior
and character, and the husband’s obligation by settlement or otherwise
to provide for the children, which he cannot but suspect to be spurious.
3 Block com. 136. See Ray v. Tucker, 51 Ill. 110; Wilson v. Sproule, 2
yeats Pa. R. 49.
The general bad character of the wife may be shown in mitigation of
damages. If it was not occasioned by her seduction by the defendant in
that case it would not necessarily reduce them to a merely nominal
sum. Clouser v. Clapper, 59 Ind. 548.
In yindictive actions, and this is now regarded as one the jury are al-
ways permitted to give damages for, the double purpose of setting an
example and of punishing the wrong doer. For these purposes proof
of the condition in life and circumstances, as well of the father and his
family as of the party committing the injury, is highly proper and
should be given to the jury. Grable v. Margrave, 3 Scam. 272.
32 Greenleaf, Sect. 55. '
,2 Greenleaf, Sect. 55; Barker v. Mosley, Bull N. P. 28; Welton v.
Webster, 7 C. and P. 198.
80 LAW OF DAMAGES,
his wife, he may introduce the letters of his wife to a friend in
the hand-writing of the defendant.* y
\
But before the letters of the wife can be admitted in evi-
dence forthe plaintiff, the fact must be established by extrinsic
evidence that they were written before the attempt at adul-
terous intercourse had been made by the defendant.*
101. The Time when the Letters were Written must be Proved by
Oral Evidence. The time when her letters were written must
The general principle upon which damages are given in case for crim-
inal conversation in England, were laid down with great clearness by an
eminent Judge Hesaid: “The action lies in this case for the injury
done to the husband in alienating his wife’s affection, destroying the
comfort had from her company, and raising children for him to support
and provide for, and as the injury is great, so the damages given are
commonly very considerable, but they are properly increased or
diminished by the particular circumstance of each case. The rank and
quality of the plaintiff, the condition of the defendant, his being a friend
relation or dependent of the plaintiff, or being a man of substance,
proof that the plaintiff and his wife having lived comfortably together
before the acquaintance with the defendant and her having always bore
a good character till then, are all proper circumstances of aggravation.
Bullers N. P. 27; see May on dam. 385.
5 2. Greenleaf on evid., Sect. 55.
If exemplary damages may be given for the seduction of the wife, of
which there is no doubt the plaintiff may recover for loss of service if he
allege and proves it, we are unable to see why the pecuniary circum-
stances of the defendant should not go to the jury to enhance the dam-
ages. Peters v. Lake, 66 Ill. 206. In acase for an assault and battery
committed upon the wife, evidence of the pecuniary circumstances of
both parties is admissible to aggravate the damages. Cochrane v.
Anmon, 16 Ill. 316; Yundt v. Hartruft, 41 Ill. 9; Peters v Lake, 6 Ill. 206.
This is an action of trespass vi et armis, but in substance is an action on
the case for seduction of the wife—the alienation of her affection from
the husband exposing him to shame, ridicule and hazard of maintain-
ing a spurious issue. Reeves on Domestic Relation, 66.
8 Welton v. Welton, 7 C. and P. 198; 2 Greenleaf on evid., Sect. 55.
On the trial of a cause for criminal conversation, ‘the plaintiff offered
in evidence a certain paper written by his wife, tending to show the
alleged criminal intercourse, but which was not sent to or ever in pos-
session of the defendant. The plaintiff was introduced and testified in
CRIMINAL CONVERSATION AND SEDUCTION. 81
be accurately proved; the date of the letters are not sufficient
for the purpose.’
102. The Wife’s Character Presumed to be Good. The charac-
ter of the wife before the alleged adulterous intercourse is pre-
sumed to have been good, and the plaintiff cannot go into
general evidence in support of it until it has been attacked
and impeached by the defendant either in cross-examination
or in chief."
108. The Plaintiff Cannot Show General Reputation to Rebut
Instances of Misconduct. The question is not quite settled
whether the husband can, after evidence has been introduced
showing particular instances of misconduct on the part of his
wife, rebut such evidence by proof of her general good reputa-
tion and character. ’ The weight of authority seems against its
admission.’ :
relation to the paper that he came home on a certain occasion and
found his wife writing it, and told her that he would take charge of it,
and did so and had it in his possession until it was attached to the
deposition of the witness; held that it was not admissible. Underwood
y. Linton, 54 Ind. 468.
72 Greenleaf evid., Sect. 57; Edwards v. Crock, 4 Esp. 39.
72 Greenleaf evtd., Sect. 58; Edward v. Crock, 4 Esp. 39; Bamfield v.
Meany, 1 Camp 460; Dodd v. Norris, 3 Camp 519; Larr v. Hicks, Bull N-
P. 296.
In fine, it is presumed till the contrary is proved, that every man
obeys the mandate of the law and performs all his official and social
duties. The like presumption is also drawn from the usual course of
men’s private offices and business, where the primary evidence of the
fact is wanting. 1 Greenleaf on evid., Sect. 40; Doe v. Tuford, 3 B and
Ad. 890-895; Champner v. Peck, 1 Stark R. 404; Pritt v. Fairclough, 3
Camp 305. ,
1 Though the general character of the wife is in issue in this action,
the plaintiff cannot go into general support of it until it has been im-
peached by evidence on the part of the defendant, either in cross-exam-
ination or in chief, but where the plaintiff can rebut the proof of par-
\
\
82 LAW OF DAMAGES.
104. The Wife’s Character and Reputation in Issue. The
plaintiff, by bringing his action, puts his wife’s character in
issue, and the defendant may attack that character and show
by way of mitigation of damages the previous bad character of
the wife,’ and he can do this under the general issue without
setting it up by way of special defense.* And he may show
for the same purpose the reputation and standing of the wife
for chastity. And he will not be confined, to her general repu-
tation and character for chastity, but may show particular in-
stances of unchastity, her letters to and general deportment
towards himself, tending to prove that she made the first ad-
vancement.®> But he will not be permitted to show the mis-
conduct of the wife subsequent to the alleged connection with
him.*
That ‘the husband connived at the adulterous inter-
course® and his criminal connection with other women.” He
ticular instances of misconduct by proof of general good character may
be doubted, and the weight of authority seems against it.
2 Greenleaf on evid., 8. 58; see Bamfield v. May, 1 Camp 460; Dodd v.
Norris, 3 Camp 519; 2 Greenleaf evid., sepa.; Farr v. Hicks, Bull N. P.
296, 4 Esp. 5 8. C.; Stephens v. Walker, 4 Esp. 51; Bales v. Hill, 1 C. and
P. 100 inst., vol. 1 sect. 54-55.
? Sanders v. Nelson, 4 N. H 501; 2 Greenleaf evid., Sect. 56.
5 Harter v. Crill, 33 Barber 283-4; Bullers N. P. 296; Hodges v. Wend-
ham, Peaks case 39; Gardenir v. Jadis, 1 Adm N. P. 24.
5 2 Greenleaf evid., Sect 56.
6 Palmer v. Cook, 7 Gray 418; Bennett v. Smith, 21 Barber 431; 2
Greenleaf evid., 8. 56; Field on dam. 563.
® 1 Stephens N. P. 26; 1 Sm N. P. 23-4.
" Bromly vs. Wallace, 4 Esp. 276.
In an action for the seduction of the plaintiff’s wife it is competent for
the defendant to prove under an answer of general denial in mitigation
of damages, that owing to the wicked and depraved disposition of the
plaintiff, he and his wife, before the alleged improper intimacy, lived
unhappily together; that the plaintiff frequently cursed, abused and
struck her, and about three years before their final separatién drove her
from home under threat of killing her. Coleman v. White, 43 Ind. 429.
CRIMINAL CONVERSATION AND SEDUCTION. 83
may also show for the same purpose the bad terms on which
the plaintiff and his wife lived together, that he mistreated
her, that his gross neglect and inattention in regard to her
conduct with the defendant, and any other fact tending to
show the little intrinsic value of |her society or the light esti-
mation which he held it. He may show for the same purpose
a want of chastity in the wife before marriage, but the jury
may also consider evidence tending to show that the unchaste
acts were with the defendant exclusively.
105. The Opinion of a Witness not Admissible'as to Affection
Existing Between Plaintiff and his Wife. But he will not be per-
mitted to show by a witness that from what he had observed
and knew of the language and conduct of the plaintiff and his
wife towards each other, there was not in his opinion any
affection existing between them at and before the seduction.”
The Supreme Court of Indiana, in the case of Vanwater v.
McKillip, in commenting on the admissibility of evidence in
mitigation of damages, says: “There are many facts and cir-
cumstances which a defendant in an action of this kind may
show in mitigation of damages, but we have met with no case
in which it has been decided that a bad temper or the occa-
sional collisions that may take place between husband and
wife in consequence of bad temper of either or both of them,
afforded the slightest extenuation of the guilt of the seducer.
The ebullition of passion soon passes away and domestic peace
and comfort, though interrupted temporarily, are not destroyed.
They inflict no wound on the husband’s honor. Why then
should these momentary outbreaks of feeling mitigate the
damages for an injury that forever destroys his domestic en-
joyment and inflicts a wound upon. his honor that cannot be
healed? What excuse can the seducer have in such unhappy
discord for his guilt? If by artfully taking advantage of them
he draws the wife off from her allegiance to her husband and
84 LAW OF DAMAGES.
weans her affection from him entirely, does it not rather
aggravate than extenuate the injury?”
106. The Fact that the Plaintiff Continues to Live with his Wife
‘may be Proved to Mitigate Damages. The fact that the husband,
after he has discovered the adulterous conduct of his wife, still
continues to live and cohabit with her, may be given in evi-
dence to mitigate the damages, but cannot be pleaded as a bar
to the action. Condonation as to the wife is not condonation
as to the defendant.*
107. The Defendant may Show in Mitigation of Damages that
the Plaintiff and Wife Lived Unhappily Together. The defendant
may show in mitigation of damages that the plaintiff and his
wife lived unhappily together, and that he treated her in an
inhuman manner, and that such treatment was produced by
1 7 Blackford 578.
2 2 Greenleaf, Sect. 56; Bromly v. Wallace, 4 Esp. 237; Felowny v. Col-
man, 2 Stark R. 191 1B. and Side 90; Jones v. Thompson, 6 C. and P.
415; Weber v. Woort, 1 M. and B. 404; Dallas v. Sellers, 17 Ind. 479.
4 Clouser v. Clapper, 60 Ind. 548; Sanborn y. Nelson, 4 N. H. 501;
Beglow’s leading cases on Torts, 338.
The defendant may show in mitigation of damages that the plaintiff
and his wife lived together as husband and wife, and that before the
alleged improper intimacy between him and the plaintiff’s wife that the
plaintiff and his wife lived unhappily together; that he frequently cursed
and abused her, and often struck her, and that at times the plaintiff
drove her from his house by beating her and by threats that he would
kill her, at the time presenting a pistol at her which caused her to fly
from her home and her children, and that this trouble grew out of the
fact that the wife wanted one of the children to wash before coming to
breakfast, and that the plaintiff determined it should not; that they after-
‘wards lived together as husband and wife, but unhappily as before, and
that they finally separated, and that the said trouble between the plain-
tiff and his wife existed on account of the wicked, depraved and selfish
disposition of the plaintiff, and not on account of any alleged improper
intimacy between the defendant and his wife. Coleman v. White, 43
and 429; see Sedgewick on dam. 547; Gilchrist v. Bale, 8 Watts, 355; Pal.
mer v. Crook, 7 Gray 418; 1 Greenleaf evid. 117; Sect. 102.
CRIMINAL CONVERSATION AND SEDUCTION. 85
drunkenness or otherwise, but the plaintiff's general character
is not in issue, but only his character as a husband; therefore
the plaintiff’s general character can not be attacked.5
108. The Amount of Damages. After considering all the
elements, the jury should award the plaintiff such damages as,
in their opinion, will be sufficient to compensate him for his
loss and suffering."
109. Elements of Damages. The court or jury in trying a
cause of criminal conversation in assessing the plaintifi’s dam-
ages, should take into consideration the “ injuries resulting
from the alienation of the wife’s affections, destroying the com-
fort had from her society, the raising of spurious children for the
husband to support and provide for, rank and social standing of
the parties, the pecuniary standing and the private and social
relation of the husband and wife, their mutual devotion or
otherwise, the enjoyment of comfort and' happiness in the
society of each, and the character of the wife previous to the
seduction.’””*
Norton v. Warner, 9 Conn. 172.
‘The action lies in this case for the injury done to the hus-
band in alienating his wife’s affection, destroying the comfort had
from her company, and raising children for him to support and
provide for, and as the injury is great, so the damages given are
commonly very considerable, but they are properly increased or
diminished by the particular circumstance of each case. The rank and
quality of the plaintiff, the condition of the defendant, his being a friend
relation or dependent of the plaintiff, or being a man of substance,
proof that the plaintiff and his wife having lived comfortably together
before the acquaintance with the defendant and her having always borne
a good character until then, and proof of settlement or provision for the
children of the marriage, are all proper circumstances of aggravation.
Bullers N. P. 27; see Moyne on dam. 385. Twenty-five hundred dollars
was held not excessive damages in the case of Clouser v. Clapper, 59 In.d
548; Hill on Torts, 509; Peters v. Lake, 66 Ill. 206; Yundt v. Handruft, 41
Til. 9.
8 Field on the law of damage, P. 563; Smith,v. Allison, Bull, 2 N. P. 27;
86 LAW OF DAMAGES.
210. Seduction, Action can be Maintained. A common law
and action can be maintained by a parent, guardian or other
person: standing in loco parentis to a female who has been
seduced, or by the husband for the seduction of his wife, or by
the master for the seduction of his servant, and this “only
when the relation of master and servant existed actually or
constructively at the time of the seduction.”?. The foundation
of the action is the loss of the service of the servant, occasioned
by the defendant’s casual intercourse with her by which she
became pregnant.’ As’a general rule the action will not lie
unless the plaintiff can show that the female was his servant,
and that the defendant had had*connection with her, and that
she became pregnant from such'sexual intercourse. But to
this rule there are some exceptions. This action will lie
against a defendant for debauching the plaintiff’s servant and
communicating to her a venereal disease by which she was
made sick and unable to labor.* It must appear from the evi-
dence that the servant has in some way been injured by reason
of the commerce between her and the defendant, for otherwise
it is in principle nothing but the case of an assault upon the
servant without damages to the master. The plaintiff's claim
for damage is founded on the legal fiction of loss of service,
and unless the evidence show that the female was in the ser-
Winter v. Henn, 6 C. and P. 494, Winter v. Wroot, 1 M. and A. 404;
Duberly v. Gunning, 4 T. R. 655; Edwards v. Crock, 4 Esp. 39; Terlang v.
Colman, 1 Band A. 90; Welton v. Webster, 7 C. and P. 198; Calcroft v.
Lord Harbaugh, 4 C. and P. 499; Wells v. Bernard, 8 Bing 376; 2 Hill
Torts 509; Hillard Remed. 398.
1 Hill v. Wilson, 8 Blackf. Ind. 123; 13 Black com. 140 Conn. Dg. 318;
Mayne on dam. 284,
? Eager v. Grimwood, 34 legal obs. 360; Bartley v. Ritchings, 4.N. Y.
38; Knight v. Wilcox, 14. N. Y 413.
® White v. Nellis, 31 N. Y. 405.
2 Greenleaf on evid., Sect. 577; see authority above,
CRIMINAL CONVERSATION AND SEDUCTION. 87
vice of the plaintiff there can be no recovery.” The reign of
fiction having passed away and vanished before the progress
of culture and civilization, the injured and humiliated female
may now, in many of the States by legislative inactments,
have redress in the courts of justice for damages in such cases.
111. Damages to Embrace Every Loss or Injury. - As a general
rule the damages will embrace every loss or injury resulting
from the wrongful act or all that the plaintiff can feel from
the nature of the injury; therefore, in case of a parent suing for °
the seduction of a daughter, the jury may “consider his loss of
comfort, as well as the service of his daughter, in whose virtue
he can feel no consolation, and his anxiety as the father of
other children"whose morals may be corrupted by her exam-
ple.” And they should also consider the disgrace cast upon
the parent and its effect on the domestic peace and happiness
of the plaintiffs family. After considering all the losses and
injuries the jury should award such damages as will recom-
pense’ the’ plaintiff for all the losses and injuries he has sus-
tained, and unless there qre mitigating circumstances they
may, in addition to this, allow exemplary damages to punish
the defendant.)
112. Aggravation of Damages how Shown. The plaintiff
may show the rank of his family, the pecuniary condition and
circumstance of the defendant, the standing of both parties
5 Hill v. Wilson, 8 Blackf. 123; Richardson v. Fout, 11 Ind. 466; Gunell
v. Wells, 7 Man. & Gran. 1,033; Ellington v. Ellington, 47 Mass. 329;
Gray v. Darland, 51 N. Y. 424; Field on the law of dam. 556
6 See Sect. 24 Ind. stat. vol. 2 Res. by G. and H. P. 55.
7 Field on the law of dam. 557 8. 698; Kendrick v. McCray, 11 Geor.
603; Andrews v. Asky,8 C. and P. 7; Phelps v. Holey, 4 Gray (Mass.) 568:
Knight.v. Wilcox, 18 Barber 568 14 N. Y. 413; Falkner v. Scarlet, 29 Ind.
154; Wilkin v. Hancock, 5 Burt 567.
1 Sargent v. Denison, 5 com. 106; Stevenson v. Belknap, 6 Iowa 97.
88 LAW OF DAMAGES.
and the natural consequence of the defendant’s act, even
though it took place after the commencement of the cause of
action, such as expense of lying in, &c., in aggravation of
damages.*
And he may show for the same purpose that the defendant
succeeded in debauching his daughter by a promise of mar-
riage. But it is not to be inferred from this that the parent
can recover damage for a breach of promise to marry. An ac-
tion for such damages must be brought by the daughter or ser-
vant alone.’ The right to aggravate the damages by showing
that the defendant debauched the daughter under a promise of
marriage, is a question, and in some States it is absolutely for-
bidden.*
Ingersoll v. Jones, 5 Barb. 661; Irwin v. Decannon, 11 East 23; Ed-
mondson v. Marshall, 2T. R, 4, Ballv. Bruce 21 Ill; 161 Bartleby v.
Richtmyer, 4.N. Y. 38
Lipe v. Esenlerd, 32 N. Y. 229; Badgley v. Decker, 44 Barber 577.
’ 8 Rea v. Tucker, 511 Ill. 110. Hewett v. Prime, 21 Wend. 79.
8 White v. Campbell, 13 Gratt 573.
* Phelen v. Kinderdein, 20 Pa. st. 354.
5 Stevenson v. Belknap, 6 Iowa 97; Grove v. Dill, 3 Iowa 337; see Whit-
ney v. Elmer, 60 Barber N. Y. 250; Moyne on dam. 284, and English cases
cited.
CHAPTER VI.
FALSE IMPRISONMENT.
Fase IMPRISONMENT DEFINED. THE RIGHTS OF PRIVATE
CITIZENS AND PEACE OFFICERS TO MAKE ARRESTS. THE
RIGHT OF A CITIZEN TO MAKE AN ARREST DISCUSSED. THE
RIGHT OF A PEACE OFFICER TO MAKE AN ARREST WITH-
OUT A WARRANT ‘THE OPINION OF THE SUPREME COURT OF
MASSACHUSETTS. THE CRIMINAL ARRESTED BY A PRIVATE
CITIZEN OR PEACE OFFICER MUST BE TAKEN WITHIN A REA-
SONABLE TIME BEFORE A COURT AND CHARGES PREFERRED
AGAINST HIM, ARREST UNDER A VOID WRIT. THE RESPON
SIBILITY OF THE PARTY CAUSING THE ARREST. JUSTIFICA-
TION MUST BE ESTABLISHED BY THE DEFENDANT, ‘THE ELE-
MENTS OF DAMAGES, AGGRAVATING CIRCUMSTANCES. Mirt-
IGATING CIRCUMSTANCES. FULL DEFENSE,
113. False Imprisonment, ats Definition. False imprisonment
may be defined to be “the unlawful restraint of a person con-
trary to his will with or without, process of law.’” In general
no actual force or manual touching of the body, no compulsory
seizure, is necessary to constitute an arrest or imprisonment.’
71 Hill on Torts, 195; Fuller v. Bueher, 11 Mich. 204.
11 Hill on Torts. A false imprisonment may be effected by threats,
and a conviction thereof sustained without proof of expressed threats or
answered restraint. Herring v. The State, 3 Tex. App. 108, Malice
need not be averred or proved to sustain the action for false imprison-
ment. Akin v. Newell; Woods v. State, 32 Ark. 605; Colter v. Lower et
al, 35 Ind. 285; Hall v. Rodgers, 2 Block 429; Mason v. Canfield, 6 Block
406; Poulk v. Slocum, 3 Block 421.
90 LAW OF DAMAGES.
If the plaintiff is compelled to move or not to move either by
threats or force against his will, he will have a cause of action
against the wrong doer.
114. The Right of Private Citizens and Peace Officers to Make
Arrests. The constitutions of most of the States forbid unrea-
sonable searches and seizures and arrests of individuals with-
out due process of law. But they do not abrogate the rules of
the common law which authorizes private persons and peace
officers to make arrests in certain emergencies without war-
rant.”
115. The Right of « Private Citizen to make Arrests. The law
is ever mindful of the rights and liberties of the people, and it
permits private citizens to make arrests in certain emergencies.
Buta private citizen will only be justified in making an arrest
where’ it appears, first, that a felon has actually been com-
mitted by some person or other against the laws of the State;
second, that the circumstances were such that any reasonable
2 Starkey evidence, 1,112. In order to sustain a charge of false im-
prisonment it is not necessary for the plaintiff to show that the defendant
used violence or laid hands on him, or shut him up in jail or in prison,
but it is sufficient to show that the defendant at any place or manner re-
strained the plaintiff of his liberty or detained him in any manner from
going where he wished or prevented him from doing what he desired.
33 Tl. 473.
Rohan v. Swain, 5 Cush. 285. In this case the court, in commenting
on this question,said: “It has been some times contended that an arrest
of this character without a warrant is a violation of the great fundamen-
tal principles of our National and State constitutions, forbidding unrea-
sonable search and arrest, except by warrant founded upon complaint
made under oath. These provisions doubtless had another different pur-
pose, being in restraint of general warrant to make search and requiring
warrant to issue only upon a complaint made under oath. They do not
conflict with the authorities of a constable or other peace officers or pri-
vate persons under limitations to arrest without warrant those who have
committed a felony.”
FALSE IMPRISONMENT. 91
person acting without passion or prejudice would have fairly ,
suspected that the plaintiff committed the crime or was im-
+ plicated in it.
And as a general rule no private person can, without
warrant, arrest another for a misdemeanor. But there are ex-
ceptions to this rule. A private person may arrest another
for a breach of the peace while the strife is going on and to
prevent its continuance. But after the strife has ended and
order restored, his authority to make arrests ceases.°
116. A Peace Officer may Arrest Without Warrant. A peace
officer is authorized to arrest without warrant when he sees
the offense committed or when he knows a felon has been com-
mitted and the circumstances are such as to lead a reasonable
man, without passion or prejudice, to suspect the plaintiff
guilty, or where it appears that he had probable and reason-
able ground to believe that the prisoner had committed a felon
against the laws of the State where the arrest is made. But to
justify a peace officer in apprehending without process for an
affray, the affray must take place in his view and be still con-
tinuing. After it is over he has no more power to arrest an
offender than any other person.’
3 Addson on Torts, 700; Griffin v. Colmer, 4 H. and N. 265; 28 Law
Exch. 134; Wright v. Coust, 4 B. and C. 596; Power v. Buckner, 3 Ind.
475; Unto v. Weaver, 41 Me. 430.
*2 Addson on Torts, 701; Hawkins P. C. chap. 12 8. 20.
_5 Poen vy. Beckner, 3 Ind. 475; Cook v. Neither, Cote 6C and P. 741;
Coupey v. Henly, 2 Esp. 540; Fox v. Gaunt, 3 B. and Ad. 798; Holley v.
Mix, 3 Wend. 350; Dering v. The State, 49 Ind. 56; Wakely v. Hart, 6
Bin, 316; 1 Hill on Torts, 210.
7 Dering v. The State, 49 Ind. 56; Poen v. Beckner, 3 Ind. 475; Cook v.
Nethercote, 6 C. and P. 741; Coupey v. Henly, 2 Esp. 540; Fox v. Gaunt,
3B. and Ad. 798.
92 LAW OF DAMAGES.
The Supreme Court of the State of Massachusetts,
in commenting upon the question of the right of private citi-
zens and peace officers to make arrests, says: “The public
safety and the due apprehension of criminals charged with
various offenses, imperiously require that such arrests should
be made without warrant by the officers of the law. As tothe
right pertaining to a private person to arrest without warrant
is a much more restricted authority, and is confined to cases of
actual guilt of the party arrested, and the arrest can only be
justified by proving such guilt. But as to constables and other
peace officers acting officially, the law clothes them with
greater authority, and they are held to be justified if they act
in making the arrest upon probable and reasonable grounds
for believing the party guilty of a felony, and this is all that
is necessary for them to show inorder tosustain a justification
of an arrest for the purpose of detaining the party to await
further proceedings under a complaint on oath and warrant
thereon.” The probability that ‘the prisoner will escape, if
not forthwith arrested, ought to have its proper effect upon the
mind of the officers in arriving at aconclusion whether he will
arrest without warrant or not.
“But the question of the reasonable necessity for an im-
mediate arrest, in order to prevent the escape of the party
charged with a felony, is one that the officer must act upon
under his official responsibility, and not a question to be re-
viewed elsewhere.’”
1 Rohan v. Swain, 5 Cush. 281-83.
? Rohan v. Swain, Sup. 1 Chitty Crim. Law 252; Hale P. C. 871 Dec.
on L. 47. Peace officers are bound upon directed charge of felony and
reasonable ground of suspicions to apprehend the party aécused. Deer-
ing v. The State 49 Ind. 56.
FALSE IMPRISONMENT. 93
117. The Law Requires a Private Citizen or a Peace Officer who
has made an Arrest to Take the Prisoner to a Court having Jurisdiction
and Prefer Charges. After a private citizen or a peace officer
has made an arrest without warrant on suspicion, he must take
the prisoner as soon as he reasonably can before an officer
having jurisdiction to examine into the nature of the offense
and file or cause to be filed a charge against him.”
118. The Legality of Arrest Under Warrant. Every man has
the right to the enjoyment of his liberty and the use of his
property, except so far as restrained by law, and who ever in-
terferes with the enjoyment of one or the use of the other is a
trespasser. A man who seizes the property or arrests the per-
son of another by legal process or other equivalent authority
conferred upon him by law, can only justify himself by a strict
compliance with such process or authority. If he fails to exe-
cute or return the process or authority as thereby required, he
may not, in the strict sense, be said to be a trespasser abintio,
but is often called such, for his whole justification fails and he
stands as if he had never had any authority to make the arrest
or take the property, and, therefore, appears to have been a
trespasser from the beginning.’
119. Arrests Under a Void Writ. It may be laid down as a
general rule that when an officer makes an arrest under a war-
rant which is in fact void, as where the court or magistrate
~ issuing the writ had no jurisdiction of the offense or subject
? Davis v. Russell, 2 Moore & Payne 90; William v. Glenester, 2 B. and
C. 699; Wright-v. Courts, 4 B. and C. 596; Bouglon v. Jackson, 11 East
L. E. 386; 1 Hill on Torts 209; Baz. et al. v. Tate, 43 Ind. 60; Law v.
Evans, 16 Ind. 486; Scorles v. Nevins, 47 Ind. 290.
« Bock v. Stimpson, 108 Mass. 520; 2 Rol. Ab. 563; Shortland v. Gar-
rett, 5 B. and C. 485, 8 D. & R. 257; Smith v.. Gates, 21 Peck 55; Coffin v.
Vincent, 12 Cush 98; Russell v. Hirab, 15 Gray 166; Monroe v. Merrill,
6 Gray 236 14 Ia. 141; Modesett v. Johnson, 2 Block 431.
94 LAW OF DAMAGES.
matter for which the warrant was issued, which fact appears
from the writ itself, or where the officer arrested the wrong
person, in all such cases the officer will be liable in damages.
to the injured party, and the writ will be no protection to him
unless the complaining party has, by his own misstatement
and misrepresentation, caused the officer to arrest him in place
of the real offender.t. But asa general rule an officer will not
be held in damages if the warrant under which he made the
arrest is fair on its face and shows jurisdiction in the officer
issuing it as against the person named in the warrant.®
120. . The Responsibility of the Party who Procured the Writ. It
is well settled that if a judicial officer, whether possessed of a
general or special jurisdiction, acts erroneously or even oppres-
sively in the exercise of his authority, an individual at whose
suit he acts is not answerable as a trespasser for error or mis-
conduct of the officer. But a judicial officer whose jurisdiction
is special and limited transcends his authority and acts in a
case in which he has no cognizance. His proceedings are
coram non judice, and no person, much less a suiter, can justify
under them.”
. 121. Where a Ministerial Officer Pleads Justification he Must
Sustain it by his Evidence. The rule is universally recognized
that when a ministerial officer justifies under authority, he
must clearly show that authority, and it must appear that he’
4 Field on dam 540; Perry v. Johnson, 31 Conn. 32; 2 Hill on Torts
185; note 189; Davis v. Jenks, 11 M and W. N.S 495; 26 L. C. P. 267; 2 /
Addson on Torts 701; Duston v. Peterson, 2 C. B. N. 8. 495; 2 mane or
Torts 701.
6 Field on law of dam. 538; Bonesteel v. Bonesteel,1C. and M. 77 733
Blyth v. Thompson, 2 Ala. Proct. 468; Farrell v. Barnett, 22 Eng. L. and
E. 179; Parson y. Harper, 16 Gront 64; Sedgwick on dam. 700; Field ‘on
dam. 538.
1 Taylor v. Moffatt, 3 Black 305; Sandcool y. Boughton, 5 Wend. 170.
FALSE IMPRISONMENT. 95
acted under a court having jurisdiction of the subject'matter,
that the process or command that he executed was on its face
legal and such as the court had the power to issue, and that
he did no more than to execute the process or command in a
legal manner.!
i
122. The Elements of Damages. 1. Bodily and mental sufter-
ing. 2. Lossof time. 38. Expenses of all kind, including attor-
ney’s fee incurred in procuring discharge. 4. Interruption of
business. The general rule for the assessment of damages,
where the evidence fails to show expressed malice, is the actual
damage suffered in consequence of the imprisonment, includ-
ing attorney fees and all other expenses incurred in procuring
a discharge, loss of time, interruption of business, bodily and
mental suffering.* And in some cases exemplary damages
have been allowed.®
1 Poulk v. Slocum, 3 Black 421; Woodkirk v. William, 1 Black 110;
Hall v. Rodgers, 2 Black 429.
In an action against a magistrate for false imprisonment of the plain-
tiff in the house of correction, it appeared by the defendant’s record that
the plaintiff was duly convicted before him of being a common
drunkard, and was thereupon sentenced to said house, and that the
plaintiff appealed from the sentence to the Court of Common Pleas, and
that upon his failure to procure sureties for the prosecution of his appeal:
the defendant issued a mittimus pursuance to the sentence. Held, that
the defendant could not be permitted to show by parol evidence, in jus-
tification of his proceedings, that the plaintiff after failing to procure
surety waived and withdrew his appeal. Kendall v. Powers, 4 Mt. 553.
* Bonesteel v. Bonesteel, 30 Wis. 511; Prichard v. Parry, 1 C. and M.
775; Blyth v. Thompkins, 2 Able Pr. R. 468; Farrell v. Barnett, 22 E. L.
E. 179; Parson vy Harper, 16 Grot (Va.) 64, Sedgwick on measure of
dam. 700 and notes; Field on law of dam. 538. ;
5 Fellows v Goodman, 49. Mo. 320.
Besides damages for the direct pecuniary injury, as by taking away or
injuring property, the jury may allow damages for indirect pecuniary
injury, where it is a necessary consequence of a direct act and when the
averment in the complaint warrant it as a loss of time, delay in business,
. expense.in, etc.,and for injury to business or profession, reputation, or |
96 LAW OF DAMAGES.
123. Matters that may be Shown in Aggravation of Damages.
The plaintiff may show in aggravation of damages that the
defendant in making the arrest and imprisonment was
actuated by malicious motives. Thus where a person was
arrested and imprisoned merely for the ‘purpose of enabling
the defendant to accomplish an object that he otherwise could
“not have done, the prosecution being a mere sham, the court
held that the circumstances went to aggravate rather than to
diminish the amount of recovery.°
124. Mitigating Circumstances, what the Defendant may Show.
The defendant may show in mitigation of damages every cir-
cumstance connected with the transaction that has a ten-
dency to show that he acted with honest motives and in good
faith in making the arrest and imprisonment. For this pur-
pose he may show that before he made the arrest he consulted
an experienced attorney, and that he followed his advice in
making the arrest. So he may show that the plaintiff insulted
him with vile epithets and gross seditious language that
caused him to make the arrest.2, And he may show for the
‘
social position and for physical suffering, as bodily pain, disability, dis-
figuration, etc., and for mental trouble, as for anguish of mind, sense of
shame or humiliation, loss of honor, all of which is considered compen-
satory and not exemplary. or punitive damages. Stewart v. Maddox,
63 Ind 51; Anthony v. Gilbert, 4 Black’348; Moffatt. v. Woodworth, 7
Ind. 83; Wilson v. Hock, 17 Ind. 227; Cox v. Vanderleed, 21 Ind. 164;
Moore v. Crose, 43 Ind. 30; Zigler v. Powell, 54 Ind. 173; Koener v.
Oberly, 56 Ind. 284.
* Fellows v. Goodman, 49 Mo. 62; Harlin v. Spaulding, 27 Wis. 360;
Buehabor v. Slegmann, 22 Mich. 300; Brown v. Carady, 39 Barber, 253;
Marsh v. Smith, 49 Ill. 396; Warrick v. Faulk, 12 Me. Weles 507, where
it was held that the plaintiff should be taken in aggravation.
? McCall v. McDowell, 1 Able U. 8. 212; Mortimer v. Thomas, 23 La.
Ann. 165; Deody U. S. C. 238; Rench v. McGregor, 32 N. J. L. 70.
2 McCall v. McDowell, U. 8. Supra.
FALSE IMPRISONMENT. 97
same purpose that the plaintiff was strongly suspected and .
accused by the public of the crime for which he was arrested.’
125. Full Defense. The defendant may defeat the plain-
tiff’s claim for damages by showing justification. If at the
time he made the arrest and caused the plaintiff to be im-
prisoned he was acting as an officer of the law and was com-
manded to arrest the plaintiff by a warrant that was valid on
its face, this would be a justification, and there could be no re-
covery.*
126. Justification by a Private Person. A private person
may defeat the plaintiff's action by showing that a felon had
actually been committed by some person or another, and that
the circumstances were such that a reasonable person acting
without prejudice or passion would have fairly suspected that
the plaintiff had committed the crime or was implicated: in it, |
or arrested him to prevent a breach of ~ peace while the
strife was as yet going on.?
8 Rerich v. McGregor, Supra.; Carpenter v. Pocker, 23 Ia. 450; May on
dam. 263; Field on dam. 541. ,
4McLane v. Cook, 23 Wis. 364; Underwood v. Robins, 106 Mass. 296;
Shain v. Davis, 55 Barber 389; Johnson v. Maxon, 23 Mich. 129; Addson
on Torts, 700-701.
, See anti-page on justification.
Ss
CHAPTER VI.
FRAUD AND DECEPTION.
FRAUD DEFINED. —THEINTENTION WILL NOT BE CONSIDERED,
MISREPRESENTATION MUST BE A MATTER OF FACT. ON
WHAT A PARTY MAY RELY. | REPRESENTATION THAT A PARTY
HAS A RIGHT TO RELY UPON. REPRESENTATION WHERE NO
RELIEF IS GRANTED. THE LAW RAISES NO PRESUMPTION OF
FRAUD. THE PLAINTIFF MAY RECOVER OR RETAIN THE
PROPERTY AND SUE FOR DAMAGES, THR DAMAGES MEASURE
OF RECOVERY. WHERE THERE ARE NUMEROUS REPRESENT-
ATIONS. DAMAGES WHERE PROPERTY IS EXCHANGED. OB-
JECTION TO THE RULE, RULE OF DAMAGES TO REAL PROP-
ERTY.
127. Fraud Defined. Fraud has been defined to be “all
acts, omissions and concealments which involve a breach of
legal or equitable duty, trust or confidence justly imposed and
are injurious to another.”
1 Burrell’s law dictionary, 1 Story Eq. 187, Sect. 193; 1 Kent 483;
Woodruff v. Garner, 27 Ind. 4; 2 Parson on cont. 775; Taylor v. Aston,
11 M. and W. 401; Warren v. Daniels, 1 Wood, &c , 181; Ainsly v. Medly,
Scott 9 Verse 13; Shackelford v. Handly, 1 A. and H. Marshall 500; Mun-
roe y. Pritchett, 16 Ala. 785, 6 Ind. 28.
If the representations of one party in a case where such representa-
tions are calculated to inspire confidence are confided in and acted upon
by another as true, when in reality they are false, and thereby the latter
is induced to contract that which he otherwise would not have made,
the law will declare the transaction fraudulent and void, without refer-
ence to the motives of the party inducing the fraud. It is sufficient in
civil cases that fraud has been committed by means adequate to deceive.
That facts without the motives furnish all the elements essential for
the law to operate upon. Bishop v. Coffet, 6 1nd. 23.
FRAUD AND DECEPTION. 99
128. It ts now Held that the Intention will not be Corisidered
Unless Exemplary Damages are Claimed. It is now generally held
that the intention of the party who misleads another to his
injury will not be considered, unless the assessment of
exemplary damages are insisted upon. It may, therefore, be
laid down as a general rule that if the statement made by the
defendant be, in fact, false and misleads the plaintiff to his
damage, it has the whole effect of fraud in annulling the con-
tract, although the person uttering the statement did not
know it to be false, but believed it to be true, or where a party
misrepresents a material fact, knowing it to be false, or made
the assertion without knowing whether it was true or false, tor
the affirmation of what one does not know or believe to be
true, is equal in morals and law as unjustifiable as the affrma-
tion of what is known to be positively false.’
These principles are upheld by sound morals, and rest on
the basis of equity and right. When a party sells property he
must be presumed to know whether the representations which
he makes of it are true or false. If he knows them to be false,
that is fraud of the most positive kind, but if he does not know
it then it can only be from gross negligence, and in contem-
plation of a court of equity representation founded on mistake
resulting from such negligence is fraud.’ |
2 Warren v. Daniel, 1 Wood and Min. 90; Ainsly v. Medly, Scott 9 Verse
13; Shackelford v. Handly, 1 A. R Marshall 500; Munroe v. Prichett, 16
Ala. 785; McConner vs. Malin, 5 Black (Ind.) 509. The doctrine is now
well settled that actual misrepresentation avoids the sale, even though
made through ignorance of the seller himself. It is said a seller is
bound with the utmost good faith, and if he misleads the purchaser by
false or mistaken statements as to any one ecsential circumstance, the
sale is voidable. Hill on venders 325.
5 Feenzel et al. v. Miller, 37 Ind. 1; Daniel v. Mitchel, 1 Story 172; 1
Story E. J. 8. 193; Ainsly v. Medley, Scott 9 Verse 13; Groves v. White,
Freem. 57; Pearson v. Morgan, 2 Brown ch. 388; Fuzan v. Toulmen, 9
Ala. 662-684; McCornie v. Malin, 5 Black 522; Turner v. Harvy, Jacob
169; Shaffer v. Slade, 7 Black 178; Burson v. Lock, 10 Verse 470; Reed y.
Devin, 7 Ind. 189.
100 LAW OF DAMAGES.
The rule is that he who sells property on a description
given by himself is bound to make good that descciption, and
if it be untrue ina material point, although the variance be
occasioned by mistake, he must still remain liable for that
variance.*
129. The Misreprcesentation Must be, to a Material Fact. To
constitute a misrepresentation a ground fraud for avoiding a
contract, or to entitle the injured party to his action for
damages, it must be in regard to a material fact operating as
an inducement to the purchaser or person making the con-
tract, and upon which he had a right to and did rely.*
130. Every Person is Conclusively Presumed to Know the Law.
Where the false representation relied upon by the plaintiff
relates exclusively to the law and not to a material matter of
fact, there can be no recovery. For no principle of law is better
settled than that every person is conclusively presumed to
know the law, both civil and criminal.*
131. A Party Cannot Rely Upon Vague Commendation. The
jury or judge trying the cause, in considering whether the
plaintiff relied upon the representations, should discriminate
between such statements as are in conscience a part of the bar-
gain and mere vague commendations, as the holding out of
* Smith v. Richards, 13 Peter U.S. 38; McFerra v. Taylor, 3 Croch.
(U. 8.) 28.
5 Cromwell v. Cliford, 45 Ind. 392; Feenzel v. Miller, 37 Ind. 1-17.
® Reed vy. Sidener, 32 Ind 373; Platt v. Scott, 6 Black 889; Clem v.
Newcastle, &c., R. R. Co. 9 Ind. 488; Louchheim v. Gill, 17 Ind. 139.
A misrepresentation, in order to effect the validity of a contract, must
relate tosome matter of inducement to the making of the contract
-where a purchaser relies on the superior knowledge and information of
the seller; not where the purchaser has equal means of information and
relies on his own judgment, founded on actual examination. Hill v.
Bush, 19 Ark. 522; Bell y. Henderson, 6 Miss. 311.
FRAUD AND DECEPTION. 101
hopes or expectations which ought to put the other party upon
further inquiry. . For it is not every erroneous representation
that a party has a right to rely upon.’
132. What Representation will be Sufficient to Enable a Party to
Rescind a Contract or to Recover Damages. The representation that
will entitle a party to rescind or to recover damages on a con-
tract, must be representations as to a fact or facts, and go toa
material matter. It must be a representation on which the
party to whom it was made had a right to and did rely. If it
be a mere matter of opinion or exaggeration, general represen-
tations of quality, capacity, value or usefulness, or be as toa
matter equally open to the knowledge of both parties, or is of
a trifling character or of an immaterial thing, or if the other
party did not trust to it or was not mislead by it, or if it was
} Gatling v. Newell, 9 Ind. 572; Foley v. Cogill, 5 Blackford 18; Post v.
Williams, 6 Ind. 380; President, &c., v. Connersville, 6 Ind. 219; Hum-
phreys v. Comline, 8 Black. 516; Morgan v. Snapp, 7 Ind. 537. ,
The defendant contends that the representations alleged to have been
made by the defendant were not such as afford a ground for an action.
It is first insisted that the statement as to the value of the lands and the
mortgage thereon were mere matters of opinion and belief, and that'no
action can be maintained upon them if false. Ifthey were such, no lia-
bility is created by the utterance of them, but all statements as to the
value of property sold are not such. They may be under certain cir-
cumstances affirmation of facts. When known to the utter to be untrue,
if made with the intention of misleading the vendee if he does rely upon
“them and is mislead to his injury, they avoid the contract. And where
they are fraudulently made of particulars in relation to the estate which
the vendor has no equal means of knowing and where he induces to for-
bear inquiries which he would otherwise and damages ensue, the party
‘guilty of fraud will be liable for the damages sustained.
Slebbins v. Eddy, 4 Mason 414-423; Mulberry v. Watson, 6 Met. 246
per Hubard J.; McClelland v. Scott, 26 Wis. 81.
When a party relies on his own judgment with means of knowing the
facts equal to those of his opponent, and he does not make use of them,
he cannot, complain. It is useless to say he was defrauded by false rep-
resentation, unless he believed them to be true and acted upon them ac-
cordingly. Jenkins v. Long, 19 Ind. 29; Hague v. Grossman, 31 Ind. 223;
Hess v. Young, 59 Ind. 379.
102 LAW OF DAMAGES.
vague and inconclusive in its own nature, or it was upon
matters of opinion equally open to the observation and inquiry
-of both parties, or in regard to which neither could presume
to trust the other, in these and like cases courts will grant no
relief. And especially will this be the case where the parties
stand mentally upon an equal footing and in no fiduciary rela-
tions."
™ Gatling v. Newell, 9 Ind 572; Hess v. Young, 59 Ind. 379; Jenks v.
Long, 19 Ind. 28; Hagee v. Grossman, 31 Ind. 223; Bowman v. Carithers,
40 Ind. 90; Kerr on frauds and mistakes, 77, note 1; 1 Parson on con-
tracts 770; Green v. Gordon, 4 Scott N. R. 13; 3 Man. & G. 446; Van v.
Cobbold, 1 Exch. 798; Edwards v. Owen, 15 Ohio, 500. Whether the repre-
sentation as to the value of the property is a mere expression of opinion
or the affirmation of a fact, is a question for the jury. Smar v. Canada,
53.N. Y. 298; 13 Am. R. 523. Our law adopts the rule of the civil law
simplex commendatis non obligat. If the seller merely made use of those ex-
pressions, which are usual to sellers who praise at random the goods
which they are desirous to sell, the buyer could not procure the sale to
be dissolved. An action of deception cannot be maintained against a
vendor for having falsely affirmed that a person bid a particular sum for
the estate, although the purchaser was thereby induced to purchase and
was deceived in the value. Neither can a purchaser obtain any relief
against a vendor for false representation of value, for value consists in
judgment and estimation in which many men differ.
Sugdon on vendors, 4 ed. 3; Harney v. Young, yelee 21; Duckinfield v.
Whihcott, 2 ch. C. 204. i
A miisrepresentation to be material, should be in respect to an ascer-
tained fact as distinguished from a mere matter of opinion. A repre-
sentation which merely. amounts to a statement of opinion, judgment,
probability or expectation, or vague rumors, or is vague or indefinite in
its nature and terms, or is merely loose conjectures or exaggerative
statements goes for nothing, though true, fora man is not justified, in
placing reliance on it. Kerr on frauds and mistakes, p. 82.
It has been frequently held that an action cannot be maintained for a
false assertion as to the value of property or the representation of the
agent of the vendor that the title was good. Hume y. Polock L. R.1
ch. App. 385; Fenton v. Brown, 14 Verse 144; Towerv. Newcomb, 3 Mer.
704; Scott v. Hanson, 1 R. and H. 129; White v. Cudden, 8 Cl. and 8S. 766;
Colley v. Gadsden, 34 Beam. 415.
The representations as to the location of the land are actionable, if the
purchaser is unacquainted with the land and had no opportunity to
examine it. Safford v. Handy, 23 Wend. 260.
FRAUD AND DECEPTION. 108
133. The Law will not Relieve a Man who has been Deceived by
his own Negligence. The law is well settled that when the plain-
tiff has been injured by his own negligence and want of proper
care in making a contract he cannot recover. He is required
to exercise his common sense and judgment, and if he fails to
exercise proper care and discretion and is thereby defrauded
and injured, courts will not extend their aid to relieve him.’
134. Representations as to the Amount the Vendor Paid for the
Property or its Value or what he has been Offered for it, the Court will
Grant no Relief. Where a vendor of real or personal property
make false representations to the purchaser as to the amount
he paid for it or its value, or the amount he has been offered
for it, and the purchaser is misled thereby to his damage, the
courts will assume that such representation are so commonly
made by those holding property for sale, in order to enhance
its value, that any purchaser who confides in them is too care-
less of his own interest to be entitled torelief.2 The same rule
applies to the common language of puffing and commendation
of commodities which are looked upon in morals as a wide de-
1 Gatling v. Newell, 9 Ind. 572, and authorities cited where the means
of knowledge is equally available to both parties and the subject of pur-
chase is alike open to their inspection, if the purchaser does not avail
himself of these means and opportunity, he will not be heard to say that
he was deceived by the vendor’s misrepresentations. Slaughter v. Ger-
son, 13 Wall (U. 8.) 379; Crouk v, Cole, 10 Ind. 485.
The cases have gone so far as to hold that if the seller should even
affirm that a particular sum had been bid by others for the property by
which means the purchaser was induced to buy and was deceived as to
the value, no relief was to be offered, for the buyer should have informed
‘himself from proper sources of the value, and it was his own folly to re-
pose on such assertions made by a person whose interest might so readily
prompt him to invest the property with exaggerated value. 2 Kent
com. 486; Georgia v. Higgenbottoms, 9 Peter 48; Craig v. Ward, 36 Bar-
ber 377.
2 Manning v. Allen, 11 Allen (Mass.) 522; Cooper v. Vanermy, 106
Mass. 79; Medly v. Watson, 6 Met. 246-260; Cross v. Peters, 1 Me. 389;
Holbrook v. Conner, 60 Me. 578, Sam. 11, Am. R. 212; Mooney v. Miller
104 LAW OF DAMAGES.
parture from the truth and injurious to the growth of virtue
and morality, yet the law does not treat them as frauds which
will avoid a contract or authorize a person who has been de-
ceived thereby to recover damages. To such the rule applies:
“The seller représents the quality or value and leaves them to
the judgment of the buyer.”
185. The Law Raises no Presumption of Fraud. It is well
settled that if there are no false representation the law will
raise none by implication, and the rule of caveat emptor, or let
the buyer take care of his own interest, applies. This rule is
apparently severe, and sometimes works hardships and seems
to clog the wheels of justice. But experience has proved its
its utility and value. “The rule never applies to cases of fraud,
never proposes to protect a seller against his own fraud, nor
to disarm a purchaser from a defense or remedy against a sell-
er’s fraud. It becomes, therefore, important to know what the
law means by fraud in this respect and what is recognized as
such fraud as will prevent the application of the general rule-
If the seller knows of the defect in his goods which the buyer
does not, and the seller is silent, and only silent, his silence is
~
102 Mass, 220; Long v. Woodman, 58 Me. 52; Hubble v. Mesis, 50 N. Y.
480; Ellis v. Andrews, 9 Ala. Law Journal 263.
Every contracting party has an absolute right to rely on expressed
statements of existing facts, the truth of which is known to the opposite
party and unknown to him as the basis of mutual engagement, and he is
under no obligation to investigate and verify statements, to the truth of
which the other party has deliberately pledged his faith. 32 N. Y. 289.
81 Story’s E. J,, Sect. 201. See Feenzel v. Miller, 37 Ind. 1 to 21.
The concealment or non-disclosure of facts to amount to a fraud must
be of those facts and circumstances which one party is under some legal
or moral obligation to communicate to the other,,and which the other
has aright to know, not merely in foso conscientia but juris et de jure.
Vanarsdale v. Howard, 5 Ala. 596; Barnett v. Stanton, 2 Ala. 181; True-
body v. Jacobson, 2 Cal. 269; Aortson v. Ridgway, 18 Ill. 23; Junkins v.
Simpson, 14 Me. 364; Young v. Bumpass, 1 Freem. ch. 241; Trigg v. Read,
5 Humph. 529; Ingram v. Morgan, 4 Humph. 529; Dickison v. Davis, 2
Ligh. (Va.) 401.
FRAUD AND DECEPTION. 105
nevertheless a moral fraud, and ought, perhaps, on moral
grounds, to avoid the transaction. But this moral fraud has
not yet grown into a legal fraud. In cases of this kind there
may be circumstances which causes this moral fraud to become
legal fraud, and give the buyer his action on his implied war-
ranty or on the deception. And if the seller be not silent, but
produce the sale by means of false representation, then the rule
of caveat emptor does not apply, ‘and the seller is answerable for
his fraud. But the weight of authority requires that this
should be actual fraud: The common law does not oblige a
seller to disclose all that he knows, which lessens the value of
the property he would sell. He may be silent, leaving the
purchaser to inquire and examine for himself, or to require a
warranty. He may be silent and be safe, but if he be more
than silent, if by acts, and certainly if by words, he leads the
buyer astray, inducing him to suppose that he buys with war-
ranty or otherwise preventing his examination or inquiry, this
becomes a fraud of which the law will take cognizance. The
distinction seems to be, and is grounded upon the apparent
necessity of leaving men to take some care of themselves in
their business transactions, the seller may let the buyer cheat
himself ad libitum, but must not actively assist him in cheating
himself.’
136. The Law Leaves Men to Judge of their Own Wants and the
Nature and Kind of Property.they Want to Buy. The law aims to
leave men to judge of their own wants and the nature, kind
and quality of the property they purchase. If the purchaser
‘choses to be his own judge and is not misled by the buyer, and
41 Parson on cont. 578; see Feenzel v. Miller, 37 Ind. 1 to 21. The
mere fact that the vendees at the time of the sale are insolvent and know
themselves to be so, and do not communicate that circumstance to the
vendors who are ignorant thereof, and know the vendors to be ignorant,
does not render the sale fraudulent and void. Powell v. Bradle, 9 Gill
and J. Md} 220.
106 Law oF DAMAGES.
in so doing cheats himself, the seller is not responsible.
Where the means of knowledge is accessible to both parties,
each must judge for himself. The above rules are in conflict
with some good authorities, but we think the weight of
authority in this country sustain them.’
137. A Party who has been Defrauded by False Representation
has one of two Remedies; He may Sue for Damages or Rescind the Con-
tract. A party who has been defrauded has one of two reme-
dies; he may rescind the contract and recover back the con-
sideration or sue for damages. If he desires to rescind, the law
requires him to be active in notifying the defendant and in
applying for his remedy. But after he discovers the fraud he
will be allowed a reasonable time to commence his action.
But it should be remembered that in the meanwhile time has
not stood still, and on recision of a contract what has fled can-
not be returned. He will be allowed to make such use of the
property as will enable him to discover the fraud or to have
the benefit of his bargain.‘
188. The Plaintiff after he Discovers that he has been Defrauded
Must be Active in Enforcing his Remedy. The bringing of the suit
to rescind a contract is not governed by the statute of limita-
tion, but it is a question of diligence on the part of the plain-
tiff who seeks to enforce the recision of the contract on the
> Hess v. Young, 59 Ind. 377; Jenks v. Long, 19 Ind. 28; Hagee v.
Grossman, 31 Ind. 223; Bowman v. Carithers, 40 Ind. 90.
Fraud may be committed by the artful and purposed concealment of
facts exclusively within the knowledge of one party and known by him
to be material, and where the other party had not had equal means of
information. Prentiss v Russ, 16 Me. 30; McLanahan v. Universal Ins.
Co.; 1 Peter 185; Jackson v. Wilcox, 2 Ill. 344; Durell v. Haley 1 p. 492.
“ Gatling v. Newell, 9 Ind. 572; Cain v. Gurther, 8 Black 409; Hills-
brook v. Burke, 22 Pick 456; Kingley v. Wallis, 14 Maine, 57; Kilroy v.
Ross, 6 Black 536; 2 Kent com. 10 ed. 664; Chandle v. Loupus, 1 st. Smith
leading cases, 3 ed. 188, 189 and 190; Lowe v. Oldham, 22 Ind. 51.
FRAUD AND DECEPTION. 107
ground of fraud. Where a bill is filed to rescind a contract
on account of fraud, the court will look to the circumstances
surrounding the transaction, to ascertain if the plaintiff has
been prompt in seeking his remedy in a reasonable time after
the facts which constitute the fraud are discovered, and grants
relief to the vigilant and denies it to the negligent.’ The facts
must appear that the plaintiff who seeks to rescind a contract
has exercised at least reasonable care in ascertaining the facts,
if readily within his power, and that he has been prompt in
commencing his action after the facts constituting the fraud
have been discovered.®
189. A Contract on Account of Mistake or Fraud Cannot be
Rescinded in Part and Affirmed in Part, but Must be Rescinded in
Toto or not at All. The law is well settled that a party who
has been defrauded cannot rescind the contract in part and
affirm it in part. Therefore, it will not permit a party to re-
pudiate a contract on account of fraud and at the same time
retain the benefit derived from it, but must, when he discovers
the fraud, restore or offer to restore to the other party what he
has received, and if he fails to do this he affirms the contract.
But the fact that the parties cannot be put precisely in statu
quo, as to the subject matter of the contract will not always
preclude a decree for recision. If the plaintiff can return to
the defendant in substance what he has received, affected only
by time and legitimate experimental use, this will be suffi-
+ Matlock v. Todd, 25 Ind. 128; Barton v. Simmons, 14 Ind. 49; Potter
v. Smith, 30 Ind. 231; Hammon v. Shields, 34 Ind. 84, 31 Maine 143.
* Matlock v. Todd, supra; Barton v. Simmon, supra; Cain v. Gurthur,
8 Black 409.
6 Johnson v. Cook, 33 Ind. 151; Negly v. Lindry, 67 Pa. st. 217; Peters
v. Gooch, 4 Elack 515; Compart v. Hedges, 6 Black 416; Shaffer v. Stead,
7 Black 178; Jenks v. Simpson, 14 Maine 364.
108 LAW OF DAMAGES. '
cient.’ If, however, the consideration received is of no value
to either party, it need not be returned.
The law not only requires the return or offer to return
everything the plaintiff has received from the defendant, but
there must also be a return or an offer to return every benefit
which the terms of the contract or its execution has conferred
upon the plaintiff. If he has received rents and profits, or if
there has been an increase among animals received, or he has
been benefited in any other way, he must return or offer to re-
turn such benefit.2 The rule is that a contract will not be re-
scinded unless both parties can be restored to the same condi-
tion that they were before it was made.’ There are,
however, afew cases in the reports where this rule has been re-
laxed and parties have rescinded a contract on account of fraud
without returning or offering to return the consideration re-
ceived. But there is none, however, that we have been able
to find in which the party seeking to rescind did not surrender
every benefit which the terms of the contract or its execution
had conferred upon him, and so far as he could had restored
the other party to his original condition, except the single
case of Daniel vy. Mitchell,’ in which, however, the court was
7 Gatling v. Newell, 9 Ind. 572; Mason v. Barrett, 1 Dennis 69; Colson
v. Smith, 9 Ind. 9; Law v. Oldham, 22 Ind. 512, Black 123; Howard v.
Cadwalider, 5 Black 135; Garret v. Headstone, ed. 349.
Millikin v. Latchem, 7 Black 136, ed. 501; Hardesty v. Smith, 3 Ind.
89; Cooley v. Hampton, 4 Ind. 451, ed. 378, 6 Ind. 26.
? Rose v. Hamly, 39 Ind. 17; Hanna v. Shields, 34 Ind. 84; Osborn v.
Dodd, 8 Black 467; Hadly v. Smith, 3 Ind. 39; Cooly v. Harper, 4 Ind. 454.
1 Johnson vy. Cookerly, 33 Ind 151; Chitty on contracts, 678-752; Hunt
v. Silk, 5 East 449; Kimble v. Cunningham, 4 Mass. 502; Conner y.
Henderson, 15 Mass. 320; Voorhees v. Earl, 1 Hill 228; Hogan v. Meyer,
5 Mass. 389; Mason v. Bonet, 1 Denio 69.
21 Story 172, The doctrine is now established by a preponderance
of authority that a party not intending to pay, who, as in this instance,
induced the owner to sell him goods on credit by fraudulently conceal-
FRAUD AND DECEPTION. 109
able to substantially restore the former status. The Supreme
Court of Kentucky, in the case of Shackeford v. Hadley, held
that where the defendant “without. the concurrence in act or
will of the injured party, that the defendant alone had fraudu-
lently produced such a change in the state of affairs that the
parties could not be put in their former condition, and great
stress was laid upon the fact that it was done for fraudulent
purposes of inflicting still further injury upon the plaintiff
that a recision could be had without placing the parties in
statu. quo.”* But the correctness of this decision has been
seriously questioned, and will, perhaps, upon further investi-
gation, be ultimately overruled.
ing his insolvency and his intent not to pay for them, is guilty of fraud
which entitles the vendor, if no innocent third party has acquired an in-
terest in them, to disaffirm the contract and recover the goods. Donald-
son v. Farwell, 93 U. S. (3 Otto) 631; Johnson v. Monellid, 2 Keys 655;
Byrd v. Hall, ed. 647; Noble v. Adams, 7 Taunt 59; Killey v. Wilson,
Ryan and Moody, 178; Bristol v. Wilsmore 1 Bam and Cress 513; Stewart
v. Emmersyn, 52 N. H. 301.
$1 A. K. Marsh 505; 4 Johnson v. Cookerly, 33 Ind. 151; Hannon v.
Shield, 34 Ind. 84.
“Fraud destroys the contract, but if a party defrauded would disaffirm
the contract, he must do so at the earliest practical moment affter the
discovery of the cheat, and he must return whatever he has received
upon it. But if the thing received is entirely valueless and a different
thing from that contracted for he may rescind the contract without re-
turning or offering to return it” Edwards on bills and promissory notes,
326. :
' 4 Colville v. Besly, 2 Denio 69. In cases of this character, the general
principle is that he who seeks equity must do equity; that the party
against whom relief is sought shall be remitted to the position he occu-
pied before the transaction complained of. The court proceeds on the
principle that as a transaction ought never to have taken place, the par-
ties are to be placed as far as possible in the situation in which they
would have stood if there had never been any such transaction Neblett
v. McFarland, 92 U.S. (11 Otto) 101; Bellamy v. Sabine, 2 Phil 425;
Samy v. King, 5 H. L. 627; Scotland v. Addie, L. R. Scotch App. 162;
Gatling v. Newell, 9 Ind. 572; Johnson y. Jones, 13 Small 580; Kerr on
frauds, 335-343. .
110 LAW OF DAMAGES.
140. The Plaintiff May Retain the Property and Sue for Dam-
ages. As has already been said, the plaintiff may, after he dis-
covers the fraud, retain the property and sue for damages.
There is some conflict among the authorities as to whether a
party who has induced another to enter into a contract by
false statement of material facts which he believed at the time
to be true, will be responsible in an action for damages. The
law is laid down by Smith in his work on contract, as follows:
“Tf the representation be not known to be false by the utterer
of it, or be not used with intent to deceive, it will not amount
to fraud although really false.”* The conflict in the decision
upon this question has been mainly produced by the nature
of the action and the character of the court trying the cause.
The courts of equity would afford relief by reforming or re-
scinding the contract, founded upon mutual mistake of fact
upon a material matter, although the misrepresentation was in-
nocently made by mistake, while the courts of law would afford
no remedy in the absence of a warranty unless there was either
positive or constructive fraud. We think that it may now be
considered pretty well settled by the most recent decisions that
in those States where the distinction between actions at law
and suits in equity and form of all such action are abolished
that an action may be maintained to recover damages for in-
jury from fraudulent representation without alleging a Scienter,
or that the defendant knew that the representations were
false.© And we are led to believe that the old rule of the com-
mon law is now being modified and expounded in such a way
4 Smith on cont. 152; Zehner v. Kepler, 16 Ind. 290.
§ Feenzel v. Miller, 37 Ind. 1; Potter v. Smith, 36 Ind. 231; Kreesan v.
Cloud, 45 Ind. 273; Brooks v. Riding, 45 Ind. 15; Ainslie y. Medly, Scott
9 Verse 21; Pearson v. Morgan, 2 Br. ch. R. 388; Burrows y. Lock, 10
Verse 470; Reed v. Duine, 7 Ind. 189; Shaffer v. Slead, 7 Black 178;
Daniel v. Mitchell, 1 Story 172; McFerron v. Taylor, 3 Cranch 281; Smith
v. Richards, 13 Peter (U. S.) 36; Fuzan v. Toulmine, 9 Ala, 662-664; Mun-
roe y. Prichett, 16 Ala, 785.
FRAUD AND DECEPTION. lit
that in an action on the case to recover for the consequential
results from fraudulent misrepresentations of matter of fact
that the plaintiff may recover, if he can show that the repre-
sentations were false and that he was injured thereby. And
this belief is based upon the ground that the party selling
property must be presumed to know whether the representa-
tion which he makes of it are true or false.’
141. The Damages. We have shown that when fraud en-
tere into a contract that the party injured has a choice of rem-
edies. He may rescind the contract and return the considera-
tion received, or he may retain the goods and sue for damages,
and where a suit is brought to recover purchase money he may
set up his damages in across action as a counter claim as a
defense to the action.’ In case of fraudulent representation of
the quality or quantity of property sold, where the plaintiff
retains the property and sues for damages, the general rule 78
that the measure of his recovery will be the difference between the value of
the property as it i3 and its value if it had been as represented.”
The rule of damages in case of a contract of sale and de-
livery of an article which proves not to conform to the repre-
sentation of it, is the difference between its actual value at the
place of delivery and what such value would be at that place
if the representations were true.’ The price paid by the pur-
* Munroe v. Prichett, 16 Ala. 785; McCormick v. Malin, 5 Black 522;
Reed v. Duine, 7 Ind. 189.
7 Smith v. Richards, 13 Peter 38; McFerron v. Taylor, 3 Cranch 281; 6
Verse 180-189, Jerimy 385-386; Cabot v. Christie, 42 Vt. 121.
1 Law v. Oldham, 22 Ind 51.
2 Groves v. Spier, 58 Barber (N. Y.) 349; Page v. Parker, 43 N. H. 368;
Carr v. Moore, 41 N. H. 131; Stevenson v. Greenlee, 15 Iowa 96; Field on
the law of damages, 568.
Sedgewick on the measure ‘of damages, 358; Moore v. Hutchison, 102
Mass. 439; Whitmore v. South Boston Iron Co, 2 Allen 52; Stiles v. White,
112 LAW OF DAMAGES.
chaser or plaintiff will be very strong, but not conclusive evi-
dence of the value of the property as it was represented to be.‘
And, in addition to this, the jury are in some cases allowed
to assess exemplary damages where such damages are allowed.®
In other cases of fraud the injured party may recover such
damages as he has sustained. Thus it was held by the
Supreme Court of the State of Texas when a drove of horses
were sold infected with a contagious disease, that if the contract
was not rescinded and the plaintiff sued for damages he would
be entitled to recover the “value of such as died and the dif-
ference in value between the surviving horses and the price
!
paid for them, with interest on these sums from the date of sale
and the value of his time, labor and expense in taking care of
them, and the injury sustained by the contagion to other ani-
mals of the purchaser without his fault.’
And it may be laid down a general rule that where the
vendor of live animals falsely represents them to be free from
infectious disease, knowing that they are not, and they are
placed by the purchaser with other animals of the plaintiff,
which take the disease and die or are injured, the owner may
11 Met. 356; Tuttle v. Brown, 4 Gray 457; Fisk v. Hicks, 11 Foster 535;
Woodward v. Shocker, 21 Vt. 580; Miller v. Eno, 4 Kenon 597; Sher-
wood y. Sutton, 1 Mason 1; Lorder vy. Kikule, 3 C. B. N. 8, 128; Dingle v.
Hare, 7 C. B. N- S. 145; Jones y. Justice law R. 32,2 B. 197; Watson v.
‘Morrison, 17 Texas 372.
§ Durst v. Burton, 47 N. Y. 167, 12 N. Y. 40, 22 Barber 154.
* Page v. Parker, 43 N. H. 363; Merny v. Jennings, 42 Conn. 9; Field
on dam. 569.
* Wheeler v. Randall, 48 Ill. 182; McAna y. Wright, 25 Ind. 22; Field
on dam. 569; Page v. Parker, 43 N. H. 363.
® Wheeler vy. Randall, 48 Ill. 182; McAmay v. Wright, 25 Ind. 22;
Sherwood v. Sutton, 5 Mason 1; Stiles v. White, 11 Met. 356; Reggio v.
Braggiotti, 7 Cush. 166; Sharon y. Mosher, 17 Barber 518; Seymour v.
. McCormick, 16 How.. 480.
FRAUD AND DECEPTION. 113
recover from the defendant all the injury he has sustained.* In
case of fraud, the plaintiff can recover such damages as may
fairly and reasonably be considered either arising naturally
a. é., according to the usual course of things, from the wrongful
act or such as may reasonably be supposed to have been in con-
templation of the parties at the time they made the contract
as the probable result, provided the representation were not
true,’ or the defendant will be held responsible for such dam-
ages as “must be presumed to have been within his contempla-
tion at the time of the commission” or perpetration of the
fraud.’ In a case where the defendant induced the plaintiff
by false representation to invest his money in an oil specula-
tion, it was held that the plaintiff could recover the money
back that he had invested and was lost, but that there must
be deducted from such money the value of the oil that the
plaintiff retained.”
142. The Rule for the Assessment of Damages Where There are
Numerous Representations. In an action for deception and fraud
in the sale of property, where the purchaser retains it and
where numerous misrepresentations in relation to the property
or in relation to several distinct particulars or qualities of the
Freeman 8 T. H. 51.
¢ Wintz v. Morrison, 17 Tex. 372; Morris v. Hutchison, 102
Mass. 439; Knowls v. Nunn, 14 L. T. R. N.S. 2 B. 592;
Sedgewick leading cases on damages, 545; Smith v. Green, 1 R. R.1 C. P.
I. 92; Mullett v. Mason, L. R. 1 C. P. 559; Jeffy v. Biglow, 13 Wend. 518,
Bradly v. Rea, 14 Allen 20; Field on damages, 569; Hadly v. Baxendale,
9 Exch. 341.
™Hadly v. Baxendale, 9 Exch. 341; Sedgewick leading cases on measure
of damages, 126; Richardson v. Dunn, 30 L. J. R. N. 8. (C. P.) 442; L. T.
R.N. S. 430.
1 Duret v. Burton, 47 N. Y. 167; Richardson v. Dunn, 30 L. J. R. N.S.
(C.P.) 2 L. T. N.8. 480, 8 C. B. N.S. 655; Carter v. Biniger 43 N. J. L.
513.
2 Carter v. Biniger, 43 N. J. L. 513.
114 LAW OF DAMAGES.
property are found to have been made by the vendor, some of
which may be materially and others immaterial, some fraudu-
lently and others honestly made, though all are false, in fact
the rule of damages is the difference between the value as it
would have been if it had been such as it was represented to
be in these particulars, concerning which the false and fraudu-
lent representations were made on which the verdict was
founded.’
148. In Case Where Property is Exchanged and Represented to be
Sound and is Not. In the case of Murry v. Jenks, where the
plaintiff exchanged a yoke of oxen for a horse of the defendant,
worth one hundred and twenty-five dollars. The horse was.
unsound, but was fraudulently represented by the defendant to
be sound. But for the unsoundness it would have been worth
two hundrsd and twenty-five dollars. The defendant wanted
the oxen for beef. The plaintiff valued them at two hundred
dollars, but there was no evidence as to their value other than
for beef. They were worth for beef one hundred dollars, and
this sum was assumed in the opinion of the court to be their
genuine market value. The court held that the rule of dam-
ages could not be affected by the circumstances that the horse
was actually worth more than the oxen, and the plaintiff was
held entitled to recover the difference between the value of the
horse as represented and its actual value.*
144. There has been Some Controversy. Over the Measure of
Damages in this Class of Cases. There has been objections urged
by law writers to the rule allowing the plaintiff in this class
of cases to recover the difference between the actual value of
(
* Page v. Parker, 43 N. H. 363; Sedgewick’s leading cases on the
measure of damages, 553.
4 42 Conn. 9.
FRAUD ‘AND DECEPTION. 115
the property at the time and its value if it had been as repre-
sented to be. They contend that the rule should be the dif-
ference between the real value of the property and the price
which the plaintiff was induced to pay. But this would give
the advantage lawfully secured to the innocent purchaser in
the original bargain, to the defendant or wrong-doer, and in
proportion, as the original price was low, would afford a pro-
tection to the party who had broken it, at the expense of the
party who was ready to abide by the terms of the contract.
And it may now be considered a settled general rule, upheld by
the great weight of authority, that in an action for fraud and
deception the measure of damages is the difference between the
actual value of the property at the time of the purchase and
its value if it had been what it was represented to be.®
145. The Rule for the Assessment of Damages in Case of Fraud-
ulent Sale of Real Estate. The rule for the asssssment of damages
for the fraudulent sale and exchange of real estate does not
differ from the rule in case of the fraudulent sale and exchange
of personal property. Thus it has been held that when the
defendant fraudulently represented the quality and location of
the land purchased by the plaintiff to be different from what
it was, that the measure of damages was the difference between
the value of the land purchased at the time of the sale and
“the sum that the land would have been worth at the time if
it had been such as it was represented to be by the vendor, to
which might be added interest ‘on the sum of difference from
the time the contract was made and money paid.®
5 Stile v. White, 11 Met. 356; Tuttle v. Brown, 4 Gray 457; Whitmore
v. South Boston Iron Co, 2 Allen 52; Fisk v. Hicks, 11 Foster 535; Wood-
ward. v. Shocker, 21 Vt 580; Miller v. Eno, 4 Keanan 590; Sherwood v.
Sutton, 5 Mason 1; Loder v. Kirkule, 3 C. B. N. 8. 128; Dingle v. Hare,
7 C. B. N. 8. 145; Jones v. Justice, Law Rept. 32 B. 197; Morse v..
Hutchins, 102 Mass. 439. ;
® Wright v. Roach, 57 Me. 600; Lickers v. Bair, 8 Iowa 368; Hirer v
116 LAW OF DAMAGES.
The Supreme Court of Indiana recently held when the
defendant sold to the plaintiff the undivided one-half of a tract
of land and falsely and fraudulently represented to him
that there was then upon such land a house of particular
size and description, which was untrue, that the measure of
damages for the lack of such house was one-half the amount of
the increase there would have been in the value of said land
if there had been such a house upon it at the time of the sale.’
(
146. The Rule for Damages Where There are False Representa-
tion as to the Quantity of Land. In case where the defendant has
made false representation as to the quantity of land, the
measure of damages is the contract price per acre for the deficit,
with interest thereon, and in case of an exchange of land proof
may be introduced to show what was the estimated value of
the property received by both parties.”
147. Where Improvement have been Made and the Vendor Pre-
vents the Conveyance, the Measure of Damages. When, after a part
performance of the contract for the conveyance of real estate
by the vendee he makes improvement on it such as were con-
templated by the contract, the vendor by his own wrongful
act puts it out of the power of the vendee to fully comply with
the provisions of the contract, the measure of damages in an
action by the vendee against the vendor for such breach is the :
Richter, 51 Ill. 299; Gates v. Reynolds, 13 Iowa 1; Mably v. Alexander,
19 Iowa 162; Hohn v. Cummings, 3 Iowa 583; Field on L. dam. 570 S. 708
' Sangster v. Prather, 34 Ind. 504; Cabot v. Christie, 42 Vt. 121.
* Lallam y. Todd, Hunter 24 Iowa 166; Boatman y. Smith, 50 Ind. 403,
FRAUD AND. DECEPTION. 117
difference between the unpaid purchase money and the actual
value of the land at the time of the breach.’
3 Case v. Walcott, 33 Ind. 5; Hopkins v. Lee, 6 Wheat-109.
The plaintiff cannot recover remote or spectlative damages; his re-
covery will be confined to the natural and proximate consequence of
the wrongful act of the defendant, Richardson v. Dunn, 30 L. J. R. N. '
8. C. P. 44.
CHAPTER VIII.
TRESPASS.
Trespass DEFINED. TRESPASS TO REAL AND PERSONAL
HROPERTY. POSSESSION ESSENTIAL TO MAINTAIN THE AC-
TION. WHEN A BAILEE FORFEITS HIS POSSESSION. AN OF-
FICER WHEN LIABLE FOR ABUSE OF HIS POWERS. THE IN7
TENTION. DAMAGES FOR INJURY TO ANIMALS, DaMAGES
WHERE PROPERTY IS TAKEN AND NOT RETURNED. DAMAGES
ARISING FROM STRIKING PLAINTIFFS HorRSE, INJURY TO
WATER PRIVILEGES. REMOVING ADAM, THE USE OF LAND
MAY BE RECOVERED. DECISION OF DAMAGES. DAMAGES
TO COAL MINES,
148. Trespass Defined. The term trespass in law. is very
comprehensive, and includes a great variety of injuries to the
person, property or relative rights of another. Blackstone
says that a “trespass, in its largest and most extensive sense,
signifies any transgression or offense against the laws of nature,
of society, or of the country in which we live, whether it re-
lates to man’s person or his property." Therefore, beating
7 3 Black com. 208.
. TRESPASS. 119
another is a trespass; taking or detaining a man’s goods are,
respectively, trespass, for which an action for trespass vi et
armis, or on the case, or in trover and conversion, is given by
law. So, also, the non-performance of a promise or under-
taking is a trespass upon which an action of trespass on the
case in assumptit is grounded, and in general any misfeasions
or acts of one man, whereby another is injuriously treated or
damnified, is a transgression or trespass in its largest sense.
But the word trespass is now used in a more restricted
sense, and means in common parlance a wrongful entry or the
taking or injuring of real and personal property, or property
of a corporal or tangible nature without the consent of the
owner. The respective writers of this subject distinguish it
from a mere conversion on the one hand, which is the subject
of an action of trover, and from a nuisance on the other.®
We propose in this lecture to treat only of trespass to real.
and personal property.
149. Trespass to Real and Personal Property Defined. Tres-
pass against real and personal property may be defined as the
injury of such property, with violence against the will of the
owner or without his consent. The violence may be either
actual or implied. Though the right of property may and fre-
quently does come in controversy in this action, yet the gist of
the action is the injury done to the plaintiff’s possession."
13 Black com. supra.
? Blackstone’s com. supra., 2; Hill on Torts 70, ed. 71. Trespass does
not lie for damages caused by building a house so near another’s land
that the same projects over and shadows and casts water drips upon the
land. Barnes v. Duffy, 7 R. I. 476; Bango v. Smith, 49 Me. 9.
52 Greenleaf evid., 8. 613.
120 LAW OF DAMAGES.
150. Who will be Regarded as Having Possession. The law
presumes that every person is in peaceable possession of what-
ever belongs to him. Property in the possession of an agent,
overseer, servant, or lessee for custody, carriage or other care or
services as a depositary mandatary, carries borrower or the like
where they have no vested interest or title to the beneficiary
use and enjoyment, and the owner may at any time take it
into his own hands and at his pleasure he may sue for any in-
jury to said property, and the possession will be considered in
him. A suit may be maintained by one in actual possession,
but on the trial he must prove his possession de facto, and an
authority coupled with an interest, as where asheriff has goods
in his possession by virture of a writ. So a tenant may sue
for an injury to the crop which is in his possession. As has
already been said, if it appears on the trial that the plaintiff
had the property in his possession at the time of the commis-
sion of the injury, the law raises a presumption that he is the
owner of it.®
151. The General Owner has a Constructive Possession. The
general owner has in law what is called a constructive posses-
sion of his property against his bailee or tenant, who have a
special property in the object injured. Thus, if one injures a
horse which he has hired or wheat which is deposited in his
grainery, or any other property intrusted to his care, he for-
feits his right to possession, and the owner may at once sue
him for such injury.*
4 1 Chitty Pleading, 188.
5 Crenshaw v. Moor, 10 Ga. 384; Hume v. Tupts, 6 Block (Ind.) 136;
Cannon v. King, 4 Ill. 9; McFarlon vy. Smith, 1 Mass. 172; Hamer v.
Welsy, 17 Wend. 91; Edwards v. Edwards, 11 Vt. 587; Lunt ¢. Brown, 13
Me. 236; Brown v. Coblaugh, 11 N. H. 557; Parson v. Dickson, 11 Pick
382; Putnam v. Wiley, 8 Johns 432; Brown v. Wase, 25 Me. 411; Gibson
v. Wood, 20 Ill. 37; Searls v. Cromle, 28 Ill. 396; Lewis v. Carsom, 15 Pa.
st. 31.
6 See.authorities above.
TRESPASS. 121
152. If an Officer by Virtue of his Writ Get Possession of
Property and Afterwards Injures It, he is Liable for Such Injury. If
an officer takes property on a lawful execution against the
plaintiff, but afterwards abuses his authority by refusing the
plaintiff the right of selection and appraisal under the exemp-
tion act, he will be treated as a trespasser from the beginning.’
If an officer levies an execution on personal property, adver-
tises it for sale, and neglect to sell it, he will be held as a tres-
passer from the beginning. This rule is based on the pre-
sumption that every man intends the necessary consequences
of his own acts. “The law in some cases judges of a man’s pre-
vious intentions by his own subsequent acts,” and on this
principle it has been frequently decided that if a man abuses
authority given him by law, he becomes a trespasser ab intio
or from the beginning. The reason assigned for this rule be-
ing that when a general authority has been given by law, the
law judges of his subsequent act quo animo or to what intent
the original act was done, but when a party himself gives an
authority or license to do anything, as to enter upon land, he
cannot for any subsequent cause convert that which was done
under the sanction of his own authority or license into a tres-
pass ab intio, and in this latter case, therefore, the subsequent
acts only will amount to trespass. For instance, the law gives
authority to a common inn or tavern, in like manner to the
_owner of the ground, to distrain damage feasance, and to ‘the
commoner to enter upon the land to see his cattle. But if he
who enters into an inn or tavern commits trespass, or if the
owner, who distrains a beast damage feasance, works or kills
5 If an officer acting under a legal warrant abuses his authority he be-
comes a trespasser ab intio. This principle is conceded on all hands.
But every irregularity is not such an abuse as makes the officer a tres-
passer from the beginning. The nature of the irregularity must deter-
mine the form of action. Jarrett v. Genathmey, 5 Black (Ind.) 237;
Freeman v. Smith, 30 Pa. st. 264; Wilson v. Ellis, 28 Pa. st. 238,
1
122 LAW OF DAMAGES.
the distress, or if the commoner cuts down a tree in these and
similar cases, the law adjudge that the party entered for the
specific purpose of committing the particular injury, and be-
cause the act, which demonstrates the intention is a trespass,
he shall be adjudged a trespasser from the beginning, or in
other words the subsequent illegal conduct shows the party’s
bad spirit, and the law raises the presumption that he was
actuated by that spirit in making the entry, and, therefore,
holds him a trespasser ab intio.6 Thus the owner of the soil,
over which a highway is located, is entitled emblements grow-
ing thereon and to the entire use of the land, except the right
which the public have to use the land and material for the
purpose of building and maintaining a highway suitable for
the safe passage of travelers.'"’ Therefore, where the defendant’s
wife, under the direction of the highway surveyor or super-
visor, cut down the grass that was standing and growing on a
public highway over the land of the plaintiff, in order that
her cnildren may go and come from school without getting
their clothes wet, and carried it away and fed it to her hus-
band’s horse, the court held that although she had a right to
cut the grass for the purpose she did, that she had no right
to carry it away, and by so doing she became a trespasser ab
intio.” So when an officer attached an attorney’s desk and
library of not more than two hundred dollars in value, situated
* Burton v. Calaway, 20 Ind. 469; Jarrett v. Gatling, 5 Blackf. 237.
™ Cole v. Drew, 44 Vt 49; Goodlittle v. Alker, 1 Burr 122; Holden v.
Shattuck, 34 Vt. 336; Perly v. Chandler, 6 Mass. 454; Stackpole v. Healy,
16 Mass. 33; Jackson v. Hathaway, 15 Johns 447.
1 Cole v. Drew, 44 Vt. 49. ,
The public can only use the road for the purpose of travel. The owner
of the fee owns the soil of the highway and the crops and embelments
thereon. Angell on highways, s. 305 et seq.; Perley v. Chandle, 6 Mass.
454; Chamberlain v. Enfield, 43 N. H 356; Garrett v. Anderson, 21 Vt.
342; Clark v. Crinth, 41 Vt. 449; Goodlittle v. Alker, 1 Burr 133; Stack-
pole v. Healy, 16 Mass, 33; Woodruff v. Nealy, 28 Vt. 165; Yates v. Joice,
11 Johns 136; Cole v. Drew, 44 Vt. 49.
TRESPASS. 123 .
in an office of a broker, kept possession of the office for more
than five hours of daylight and then, after demanding and be-
ing refused the key, obtained one from a locksmith for the
purpose of continuing his possession. The broker caused an-
other lock to be put-on the door, and after giving the officer
notice to remove the goods immediately, and on his refusal to
do so, locked him in for the night. In an action for an assault
and false imprisonment, the court held that the plaintiff’s de-
lay in removing the goods for such an unreasonable length of
time, that he abused his authority and became a trespasser
from the beginning, and that he could not recover.’
153. The Intention Make the Wrong. If a party enters upon
a piece of land in good faith, under the belief that he has a
. title thereto, he is not a trespasser, eee the title be in fact
in another.’
154. Case Where Individuals are Injured and Have no Remedy,
There are many cases in which individuals sustain an injury
for which the law gives no action, for instance pulling down a
house or raising bulworks for the preservation and defense of
the government, or to remove a building to prevent the spread
of fire, etc. The maxim of the law is that private mischief is
to be endured rather than public inconvenience. But the right
to destroy private property for the public good is only permitted
in case where there is reasonable grounds to believe it to be
necessary.* ‘
155. The Damages. The plaintiff, as a general rule, in an
action for trespass, may recover all the damages that necessarily
2 Williams v. Powell, 101 Mags. 467.
3 Am. R. 396, 3 Miss. & Tenn. R. Co. v. Deaneny, 42 Miss. 555.
4 Connell v. Emric et al., 2 Ind. 35; Kent’s com. 2 vol. 238.
124 LAW OF DAMAGES.
result from the trespass; that “every person who does a wrong
is at least responsible for all the mischievous consequences
that may reasonably be expected to result under ordinary cir-
cumstances from such misconduct.” “Where one does an
illegal or mischievous act, which is likely to prove injurious
to others, or when he does a legal act in such a careless and
improper manner that injury to a third person may ensue, he
is answerable in some form of action for all the consequences
which may directly result from his conduct.”* Indeed, it may
be laid down as a general rule that a tortfeasor is responsible
for every injury which is the natural and probable consequence
of his misconduct. He is not only liable for injuries directly
or immediately following from his wrongful act, but also for
such consequential injuries as, according to the common ex-
perience of men, are likely to result from his unauthorized act
And he will not be exonerated from liability by the fact that
intervening events or agencies contributed to the injury. The
court or jury trying the cause should inquire whether the in-
jury was such, according to common experience, and the usual
course of events might reasonably be anticipated.’
156. Damages for Injury to Animals. In all cases of trespass
the law measures the damages by the injury received, and in
some cases where great aggravation is shown exemplary dam-
ages may be allowed. And where an action is brought for in-
jury to animals, not resulting in their destruction, the measure
of damages will be the difference in the value of the property
with the injury and its value before the injury, and all neces-
sary medical expense, including careful attention and the value
of the use of the property while disabled and unfit for use.
® Per Pollock C. B. in Rigby v. Hunt, 5 Exch. 243.
® Vanderburgh v. Lenox, 4 Denio 464.
' Derry v. Fletnir, 118 Mass. 131.
*1C. RB. R. Co. v. Finegan, 21 Ill. 648; Hass vy. Borders, 1 Gil. 46;
TRESPASS. 125
157. Damages Where Property is Taken and not Returned. In
an action to recover damages for the unlawful taking of per-
sonal property where it has not been found or returned, the
owner may recover for loss of time necessarily and reasonably
expended in searching for the property, as well as the “ex-
pense thereby in addition to the value of the property and in-
terest on the same.”
158. Damages Arising from Striking Plaintif?s Horse. In an
action for damages accruing to the plaintiff from the de-
fendant’s wrongfully striking the plaintiff's horse attached toa
sleigh, and causing them torun so as to throw off the load of
wood then upon the sleigh, the court held, in determining the
plaintiff's actual damage, it was proper to consider as elements
thereof the labor and trouble of reloading the wood, the delay
in getting to market or place of destination, the time and ex-
pense lost and incurred in making repairs to the harness and
sleigh, and the injury done to the horses by causing them to
run away, though they were not physically injured thereby—
such acts of running away having a tendency to create a
vicious habit.?
i
159. Injury to Water Privileges. The Supreme Court of the
State of Illinois in a case where the plaintiff brought suit to
1
Street v. Eoumier, 34 Mo. 469; Edwards v. Beebe, 48 Barber 106, Mc-
Laughlan v. Bangor, 58 Me. 398; Watson v. Lisborn, Bridge 14 Maine
201; Gillett v. West. R. Co., 8 Allen 50, 102 Mass. 80, 17 Ala. 391; United
States v, Morgan, 3 McClane 171; Mitchell v. Bellezeber, 17 Ala. 391.
Where one sued for the interruption of the use of the mill, the court
held that the plaintiff could recover all the damages resulting from the
trespass. 8 Pick 356. 3
. 4 Oleson v. Brown, 41 Wis. 413.
The measure of damages in an action against a sheriff for a wrongful
seizure and sale of the plaintiff's goods on an execution against a third
person, in case where the plaintiff has bought back the goods from a
third person who purchased them at sheriff’s sale, is the sum paid to
regain them, not exceeding, however, the market value.and in addition
any special damages alleged and proved, Sprague v. Brown, 40 Wis. 612.
126 LAW OF DAMAGES.
recover damages for an injury to the water in his well, etc., in
commenting on the question of damages, says: “On the trial
below appellant offered to prove how much it would cost to
obtain a supply of good water by purchasing the rights from
the Water Works Company, or by the construction of a cistern.
The court refused to permit the introduction of the evidence,
and that decision is assigned as one of the errors in this record.
If the erection of the gas works produced injury to the
appellee’s well and poluted the water, he has the undoubted
right to recover a sum sufficient to cover any loss he has there-
by sustained. The company has the right to so use their
franchise as to produce no injury to the rights of others.
When they obtained their charter there was no implied duty
imposed that they should not in its exercise deprive or even
incommode in the exercise of their rights without, becoming
liable to respond in damages. In ascertaining. the true
measure of such damages, all the circumstances connected with
the injury are proper to be considered by the jury. In this
case it may be a fair measure of damages to ascertain the costs
of furnishing a sufficient quantity of water equally pure with
that which supplied the plaintiff below from his well before its
injury by the gas works. When the cost is ascertained and
the costs of keeping the conductor and other machinery in re-
pair, the allowance of such a sum as would produce an annual
interest sufficient to furnish the water from the company and
make the repairs would be a fair measure of damages. But if
the supply when thus obtained was inferior in salubrity or
taste, that should also be taken into account. So, ifthere was
danger that it would not be permanent or of an inferior quality,
would be of less value than if supplied with an abundance of
water of a good quality, if the resort to a cistern as the only
means of replacing the proper supply of water, then the
quality should be taken into consideration, and if inferior in
quality that fact should have itsdue weight. Andother means
of arriving at the damages would be to ascertain the depriva-
TRESPASS. 127
tion of the value of the property by the erection of the gas
works.”
‘
160. In Case of Injury to Water Rights Actual Damages may be
Recovered. In case of an injury to water rights or from water,
the measure of damages is the same as that allowed for injury
to the soil. And it may be laid down as a general rule that
whereby the wrongfully act of the defendant the land of the
plaintiff has been injured-by overflow, or his rights and privi-
leges in a stream of water have been abridged or destroyed, he
may recover damages where the injury is less than the total
destruction of his right, but if the injury is of a permanent
character the damages will be the difference between the value
of his property or right before the injury and immediately
afterward.?, But when the injury is but slight, the rule is dif-
ferent in cases of this kind. The plaintiff must use reasonable
care and diligence to protect himself from injury, and he can
recover only such damages as he could not avoid by the exer-
cise of the required care and skill and the use of reasonable
means and expenses and value of the time spent for such pur-
poses.*
161. Where the Defendant Damaged the Plaintiff's Sluceway,
the Measure of Damages. In one case where the defendant had
destroyed the sluceway to the plaintiff’s mill, the court held
that the plaintiff could recover the damages to the sluceway
and the value of the use of the mill during the period he was
thus deprived of the use of it or its rental value. “But in this
s
3 Ottowa Gas Light Company v. Graham, 28 Ill 73.
2 Field on damages, 597; Schuylkill Nav. Co. v. Forr, 4 Walls 362; Un-
derwood v. N. W Scythe, Fort 38 Me. 75; Bryan v. Gidden, 36 Me. 36;
Lawrence v. G. N. W. RB. Co., 16 Q. B. 643.
3 Potter v. Long, 58 Barber 278.
128 LAW OF DAMAGES.
case, as in all others of a similar character, the court held that
the plaintiff could not recover for injuries or such losses,.as he
might have avoided by reasonable care and diligence in the
use of the means in his power.‘
162. Damages for Removing a Dam. Where the defendant
wrongfully pulled the plaintiff's mill dam down and thereby
prevented the flow of water to his mill wheel, and by reason
thereof his mill stood idle for several months, the court held
that the plaintiff could recover an amount sufficient to repair
the injury to the dam and the demunition of the plaintiff's
profits on account of the mill standing idle.®
168. The Use of the Land may be Recovered. The owner of
land may recover the value of the use of the land from a dis-
ewor for the time he has been kept out of possession. But he
cannot recover the crop grown by the diseizor while he was out
of possession.®
164. Damages for Cutting Timber. The law is pretty well
settled that when one cuts timber on another’s land and man-
ufactures it into spokes or staves or cuts it into fire wood, the in-
jured party in an action for damages may recover the value of
timber, spokes, staves or wood at the time they were cut,
shaped or became chattles.®
‘Hammond y. Reese, 16 Me; 171; Fralton v. McGally, Peak N. P. 205;
Haskins v. Phillips, 3 Ex. 168; Luken y. Godrell, Peak C. 15; Field on-
dam., 592. °
5 White v. Marly, 8 Peck 356.
* Berry v. Fletcher, 1 Dill (C. C. R.) 67; 2 Stark on evid., 807; 2 Hill on
Torts, 464.
* Bement v. Thompson, 13 Ind. (N. C.) 146; Field, on damages, 593;
Moody v. Whitney, 38 Me. 174; Smith vy. Gonder, 22 Geo. 353; Cushen v.
Longfellow, 26 Me. 306; Morton v. Porter, 5 Mass. and W. 361.
TRESPASS. 129
But in case where an action is brought for cutting down.
and destroying shade, ornamental or fruit trees, the plaintiff
can recover the value of the trees for the purpose for which
they were used.” But in this, as in most other wrongful acts,
the law looks at the intention of the party, and where the cut-
ting of the timber was by mistake the measure of damages
will be only the actual loss sustained.!
165. For Cutting and Removing Soil the Measure of Damages is
the Actual Injury Sustained. In an action for cutting and remov-
ing soil, the plaintiff should be allowed such damages as will
fully compensate him for the injury and loss he has sustained,
provided no aggravated circumstances are shown. In some
cases the damages have been estimated by considering the ex-
pense of restoring the soil. But where the injury is great and
the expense of restoring the soil would exceed the value of the
land at the time or just before the injury, then this manner of
estimating cannot be resorted to, and the plaintiff will be
allowed as damages the difference between the value of the
-land just before and its value after the injury? And where
the premises are rendered worthless, then the value of the land
before the injury may be recovered. And in no case can the
plaintiff recover an amount in excess of the value of the land
or property injured, except in those States where exemplary
damages are allowed.
7 Whitebeck v. N. Y. C. N. R. Co., 3 Bar. 644.
1 Zahla et al. Mining Co. v. Isley, 40 Geo. 479; Perkins v. Hockelman
26 Miss. 41.
2 Jones v. Gooday, 8 M. and W. 146; Muller v. St. Louis R Co., 31 Mo.
262; Stock B. Iron Co. y. Conn. Iron Co., 102 Mass. 80; Field on dam.,
592; White v. Mosely, 8 Pick 356; Seeley v. Alden, 61 Pa. st 302; Mc-
Knight v. Roctriff, 8 Wright 168; Douty v. Bird, 10 P. F. Smith, 48;
Fasyth v. Palmer, 2 Harris 98; Hart v. Evans, 8 Barr 22; Walker v.
Smith, 1 Wash. C. C. R. 1,544, Dallas 206.
130 LAW OF DAMAGES.
166. Consequential Damages. In one case where the plain-
tiff was the owner of a cotton mill propelled by a stream of
water, the defendant prevented him from using his mill by
erecting a dam across the.creek just below the plaintiffs mill
that interfered with the operation of the cotton mill by back-
ing the water upon the plaintiff’s mill wheel and decreased
the capacity of the plaintiff’s mill to his damage. The court,
on the trial of the cause after reviewing the authorities, held
that wherever a loss of profit is the natural and necessary re-
sult of the act charged such as the party probably would have
made—not what by chance he might have made, but what
any prudent:man must naturally have made—evidence has
been most usually admitted as to them.*
167. Division of Damages. The question as to the division
of damages from an injury to real property arises occasionally
in cases where a tenant sues for an injury to the leasehold
property. But the question can be solved without much diffi-
culty by inquiring into rights of the parties. The tenant has
no interest in the freehold, except a temporary use and occupa-
tion. The landlord is the owner in fee of the land, and hence
whatever is calculated to produce a permanent injury to his
premises affects his interest. The tenant while in possession
may recover damages for an injury to his temporary use and
occupation, and the landlord for injuries that permanently
affect his land.” Where a tenant leased a certain-building and
premises in Baltimore, which was used as a bowling alley, and
agreed to keep the same in good repair, the adjoining owner
being lessor made an excavation and demolition on his
property in such a negligent and careless manner that the
plaintiff's bowling alley was about to fall. The defendant, see-
ing the injury that was likely to occur, obtained permission
? Simmons v. Brown, 5 R. I. 299; White y, Mosley, 8 Pick 356,
TRESPASS. 181
from the plaintiff to enter the premises and secure the wall
and make other repairs, with the proviso that the work should
be done 1n a skillful and substantial manner. The defendant
pursuant to said agreement entered the premises and com-
menced the work. He soon after completed the same. In
making the repairs he faile to use proper material and that
skill and care that he should have done. For these reasons
the whole wall soon after fell down and caused to fall a large
part of the bowling alley building. The plaintiff brought suit
for damages and alleged that by reason of the acts and negli-
gence of the defendant his entire business was broken up and
destroyed, and his customers and patronage prevented and the
use and occupation of the messuage and building made im-
passible.” The court held that the measure of damages was
the loss sustained by the plaintiff in consequence of the negli-
gence and unskillfulness of discharge by the defendant of a
commission he had undertaken to perform.’
168. The Tenants’ Damages. The law seems to be pretty
well settled that ordinarily a tenant can only recover damages
for the actual injury received, ‘and that the maximum limit of
his recovery would be the value of his lease. But to this rule
there are some exceptions that we will notice. When it ap-
pears “by the terms of his lease that he is bound to restore
the premises in as good condition” as they were where he took
possession, damages may exceed the value of the lease. In
such case he could recover damages sufficient to enable him to
put the premises in as good condition as they were at the com-
mencement of his lease, provided it does not exceed the value
of the premises.‘ “Inan action by atenant against reversioner
for trespass it has been held that the plaintiff should recover
? Gilbert v. Kennedy, 22 Mich. 117; Seely v. Alden, 61 Pa. st. 302.
§ McHenry v. Marr,'39 Md. 510; McGuin v. Grant, 1 Dutch N. J. 356.
Walter v. Post, 4 Abb. Pr. 382, 8. C.6 Duer. 363; Field on L. Dam. 595,
132 LAW OF DAMAGES.
his actual loss sustained, but if the action is against a strariger
and wrong-doer the tenant is entitled to recover the full
amount of injury to the ee he being treated as the
owner.”
169. Damages in Cases of Injury to Mines. Where a de-
fendant in working his coal mines broke through the barrier
and worked the coal under the land of the plaintiff and raised
it for the purpose of sale. Held, in an action for damages, that
the plaintiff could recover the value of the coal when it was
gotten out without deducting the expense of getting it out.’
But when there is no wrongful purpose or wrongful negligence
in the defendant, compensation for the real injury done is the
purpose of all remedies, and if courts will constantly keep this
rule in view they will have but little difficulty in managing
the forms of actions so as to secure a fair result. And if a de-
fendant has dug and taken from the plaintiff's mines coal
through mistake, and was in no way guilty of an intentional
wrong, then the measure of damages should be the value of
the coal in the mines and the damage to the land his mining
may have caused.’ As has already been said that in all cases
of willful trespass the plaintiff is entitled to recover full com-
pensation for all injuries resulting from the wrongful act.
* Field on the law of damages, p. 395.
The Supreme Court of New York held where the action was for the
loss of a life estate that the damages should be estimated by a calculaiton
of the length of time the plaintiff would probably live, then take the
annual rental value of the land, deducting taxes.
» Martin v. Porter, 5 Mees. and W. 351; Sedgwick’s leading cases on
the measure of damages, 677; Parton Coal Co. v. Cox et al., 39 Md. 1.
Heard v. James, 49 Miss. 236; Field on law of dam., 601; South Branch
Dock Co. v. Dunlap, 32 Ill. 207; Martin v. Powell, 32 B. 278.
* Fayth v. Wells, 41 Penn. st. 291; May v. Tappan, 23 Cal. 306; Cham-
berlain v. Collison, 45 Iowa 429; Stockbridge Iron Co. v. Stove Iron
Works, 102; Mass. 80.
TRESPASS. 133
Therefore, if it be made to appear in an action of trespass for
breaking and entering the plaintiff’s coal land and making ex-
cavations there-under and removed the coal from its original
bed and thereby injures the remaining coal left as pillars, or
by bad mining or otherwise renders it difficult or impossible
for the plaintiff to get out or remove such pillars or remaining
coal, or render the mines of less value to him, he is entitled to
recover the price of the coal removed, and in addition all dam-
ages to the mines resulting from the acts and conduct of the
defendant.*
4 Sedgwick leading cases on damages, note p. 684.
CHAPTER IX.
MALICIOUS PROSECUTION.
Matictious PROSECUTION DEFINED. PropasLE Cause Dr-
FINED. THE DEFENDANT WILL BE RESPONSIBLE IF HE HAD
NO EVIDENCE OF THE PLAINTIFF’S GUILf WHEN HE COM-
MENCED THE PROSECUTION. EVIDENCE THAT WILL SHOW A
WANT OF PROBABLE CAUSE. MALICE AND WANT OF PROBA-
BLE CAUSE MUST CONCUR. WHAT THE PLAINTIFF MUST
PROVE. A FULL DEFENCE. ELEMENTS OF DAMAGES. Dam-
AGES. MITIGATING CIRCUMSTANCES. THE PROVINCE OF
THE JURY.
170. Malicious Prosecution Defined. The law is well settled
that when one maliciously and without probable cause prose-
cutes another in a civil or criminal action, and the prosecution
is at end and the party has been damaged thereby, he may
maintain an action against the wrong-doer for the recovery of
his damages."
12 Greenleaf on evid., 8. 449; Reed v. Taylor, 1 Taunt 616; Wood v.
Buckly, 4 co. 14; Price v. Thompson, 6 Pickering 193; Star vy. Crocker,
24 Pickering 2; 2 Greenleaf on evid., Sect. 449; 1 Hill on Torts, 412.
MALICIOUS PROSECUTION. 135
171. Probable Cause Defined. Probable cause may be de-
fined to be “that apparent state of facts found to exist upon
reasonable inquiry, that is such inquiry as the given case ren-
ders convenient and proper, which would induce a reasonable,
intelligent and prudent man to believe the accused person had
committed in criminal cases the crime charged, and in civil
cases that a cause of action existed against him.’
172. Probable Cause to be Determined by the Court. “The pre-
vailing law of reasonable and probable cause is that the jury
are to ascertain certain facts and the judge is to decide whether
these facts amount to such cause. But among the facts to be
ascertained is the knowledge of the defendant of the existence
of those which tend to show reasonable and probable cause, be-
cause without knowing of them he could not act upon them,
and also the defendant’s belief that the facts amounted to the
offense which he charged, because otherwise he will have made
them the pretext for prosecution. In other words reasonable
and probable cause must appear not only to be deducable in
point of law from facts, but to have existed in the defendant’s
mind at the time of the proceeding, and, perhaps, whether
they did so or not is rather an independent fact for the jury to
be decided on in their view of all the particulars of the defen-
3 Richter v. Koster, 45 Ind. 440; Lacy v. Mitchell, 23 Ind. 67, Hays ~
Blizzard, 30 Ind. 437; Lawrence v. Laming, 4 Ind. 194.
The mere belief that a person has been guilty of a crime is not suffi-
cient to authorize a criminal prosecution against him. Hays v. Blizzard,
supra. But where the facts known to the prosecutor or information re-
ceived by him from sources entitled to credit are such as to justify the
belief in the mind of a person of reasonable intelligence and caution that
the accused is guilty of the crime charged and the prosecution is in-
duced thereby, such a state of facts constitutes probable cause, though it
may subsequently appear that he was not guilty.
136 LAW OF DAMAGES.
dant’s conduct than for a judge to whom the legal effect of the
facts only is more properly referred.’”
173. Sf the Plaintiff was Guilty, but it was not Known to the
Defendant at the Time he Commenced the Prosecution, it will Avail Him
Nothing. The gist of this action is malice or bad intentions,
and if the defendant at the time he commenced the prosecu-
tion of his suit against the plaintiff had not sufficient evidence
to establish a probable cause he will be responsible, notwith-
standing the fact that the plaintiff was guilty of the charge
preferred. The facts constituting the probable cause must be
known to the defendant at the time he commenced the prose-
cution.© And it is now well settled that a mere belief that a
person has been guilty of a crime is not sufficient to authorize
a criminal prosecution.® But where the facts known to the
prosecutor or the information received by him from sources en-
titled to credit are such as to justify the belief in the mind of
a person of reasonable intelligence and caution that the accused
is guilty of the crime charged and that the prosecution is in-
duced thereby, such state of facts constitute probable cause
though it may subsequently appear that the accused is inno-
cent.’
* Turner v. Amble, 10 Queen’s Bench 2525, see also Delegal vy. Higby,
3 Bing. N. C. 950; Galloway v. Stewart, 49 Ind. 156.
* Galloway v. Stewart, 49 Ind. 156; Lacy v Mitchell, 23 Ind. 67.
° Lawrence y. Lanning, 4 Ind. 194; Stone v. Stevens, 12 Conn. 219;
Delegal v. Higby, 3 Bing N. C. 950; Seibert v. Price, 5 Watts and Seg.
438; Fosha v. Ferguson, 2 Denio 617.
Facts not known to the defendant at the time he proeured the plain-
tiff’s arrest are not competent to show pr esence or absence of probable
cause Cecil v. Clark, 17 Md. 508.
" Hays v. Blizzard, 30 Ind. 457; Bacon v. Towne, 4+ Cush. 238; Addison
on Torts, 613; Lacy v. Mitchell, 23 Ind. 67.
Mere general reputation will not alone constitute probable cause. For
a prudent man in instituting an important criminal prosecution would
ordinarily look farther and inquire for testimony. Barron y. Mason, 31
Vi. 189.
MALICIOUS PROSECUTION. 137
174. What will Show a Want of Probable Cause. The author-
ities all concur in saying that the plaintiff in order to make
out his case must prove malice and a want of probable cause,
and if he can establish the fact that the defendant at the time
he commenced his prosecution against him was not in the pos-
session of such facts and circumstances as would lead a careful
and conscientious man to believe that the plaintiff was guilty,
or that there was a cause of action existing against him, he
will have succeeded in establishing a want of probable cause.’
175. What the Plaintiff Must Prove. Perhaps no point, of
law is better settled by the authorities than that in every case
of malicious prosecution the plaintiff in order to maintain his
action must prove that the prosecution was malicious and
without probable cause; and he must show that both of these
concurred. If the defendant instituted the prosecution
maliciously and it was unfounded, but there was probable
cause or such evidence as would have led a reasonable, intelli-
gent and prudent man to believe that the plaintiff was guilty
as charged, or that the defendant had a cause of action against
him, there can be no recovery.’ -
176. There can be no Recovery Where There isa Want of Malice.
And the authorities all agree that where there does not exist
a reasonable or probable cause for the prosecution that the pe-
1 Mitchell v. Jenkins, 7 B. and Ad. 588-594; Johnston y. Sutton, 1T.
R. 510.
Probable cause such a suspicion as would induce a reasonable man to
commence a prosecution, Ulner v. Leland, 1 Greenl 135, or a reason-
able ground of suspicion, supported by circumstances sufficient to’war-
rant a cautious man that the party is guilty of the offense. Calbaness v.
Martin, 3 Duer. 454.
2 Farmer v- Darling, 4 Burr 1971; Stone v. Crocker, 24 Pick. 81-83; Bell
y. Graham, 1 Natt. and M. C. 278; Hall v. Suydam, 6; Barber S. C. 83;
Richy v. Davis, 11 lowa 124; Kirkpatrick v. Kirkpatrick, 39 Pa. st. 288;
Arbuckle v. Taylor, 3 Dawl. 160; Turner y. Turner, Gam. 202; Greenlea
on evid., Sect. 453.
188 LAW oF DAMAGiis.
fendant will not be responsible in damages where there is a
want of malice. But malice may be.inferred or proved by cir-
cumstances. Ina legal sense any unlawful act done inten-
tionally, willfully or purposely to the injury of another, is as
against that person malicious.’ ‘S
177. The Fact that the Defendant had been Guilty of Other Simi-
lar Offense or that He was Reputed Guilty will not Establish a want of
Probable Cause of Malice. In the case of Barron v. Mason the
court, in commenting on the question of malice and probable
cause, said: “If it be admitted by the testimony that the
plaintiff has been guilty of other similar offenses, or that he
was reputed guilty, and that this had come to the knowledge
of the defendant before he instituted proceedings, the prosecu-
tion has no legal tendency to show either probable cause or
want of malice in ordinary cases, such aslarceny. It must also
be admitted, we think, that in that class of offenses where the
gist of the crime consists of the bad purpose which an act
otherwise innocent is done, this kind of testimony is admissi-
ble even upon the question of actual guilt, and much more
upon that of probable cause, for probable cause is not to be con-
founded with actual guilt. Probable cause is only such a state
of facts and circumstances as would lead a careful and con-
scientious man to believe that the plaintiff was guilty. This
case only requires that the defendant, upon prudent and care-
5’ Commonwealth v. Snelling, 15 Pick. 321-330; Stokely v. Harding, 8 C.
and P. 11; Mitchell v. Jenkins, 7 B. and Ad. 588-589.
Where the malicious prosecution of the plaintiff by the defendant was
on the charge of maliciously breaking down and leaving open a fence
between the land of the plaintiff and of the defendant, the dividing line
between which had been settled by arbitration in an action to recover
damages for such malicious prosecution, evidence of prior wrongful re-
moval of the fence before the submission of arbitration cannot be shown
by the defendant to prove a probable cause for the prosecution. Tillot-
son v. Warner, 3 Gray 574.
MALiciovUs PROSECUTION. 139
ful inquiry, shall find the reputed or declared existence of such
facts as indicate guilt with reasonable certainty. Mere general
reputation will not alone constitute probable cause, for a pru-
dent man in instituting an important criminal prosecution
would ordinarily look further and inquire for testimony. But
this he might fairly believed existed short of being told so by
the witnesses themselves. It is notoften the case, perhaps, that
a public prosecuting officer before making complaint have an
opportunity to converse personally with the witnesses, but they
should know something more than a mere vague general re-
port of guilt. They should have information with such dis-
tinctness and certainty as to gain credit with prudent men of
the existence and susceptibility of proof of such facts as to
show guilt, or which the defendant upon proper advice sup-
posed would constitute ‘guilt. This is the fair result of the de-
cided cases of common experience upon the subject. Now in
the class of cases referred to where the guilt or innocence of the
act depends upon motives, the conduct and declarations of the
party as to other similar transactions about the same time are
always admissible to prove actual guilt. As for instance, the
case of passing or having in possession with intent to pass
counterfeit coin or bills, it is familiar that the prosecutor may
give in evidence other similar oftenses committed by the ac-
cused about the same time for the purpose of showing nis in-
tent in the particular transaction. So also in case of embez-
zlement and some other similar offenses, and the rule would,
no doubt, extend to the proof of the very fact which the court
in this case told the jury had no other effect but to mitigate
damages. * * * We should infer that the court below did
not regard the question of malice as directly and independently
involved in the case. From what of the charge is given in
the question of malice seems to have been treated as a mere
inference from the proof of the want of probable cause, and so
it is prima facie, but nevertheless it may be disproved by a
great variety of proof of a much lower grade than that which
140 LAW of DAMAGKS.
is requisite to show probable cause. For this purpose common
repute not only as to general bad character, but also as to the
particular offense, may, we incline to think, be shown, for
this latter is nothing less than the declaration of third parties
that the plaintiff was guilty of the particular offense which is
declared admissible. * * * It is undeniable that the gen-
eral belief of one’s guilt in regard to particular offenses will in-
fluence to a certain extent the conduct of the most prudent
prosecutor in regard to instituting proceedings. How then
can it be said that it has no legitimate bearing upon the ques-
tion of malice? We think that it is impossible to so hold
without violating the most obvious principle of human ex-
perience and human conduct.t * * * And general bad
reputation is often a direct element in proof of respondent’s
guilt where he offers proof of good character in exculpation.
This testimony was admitted to go the jury upon the question
of damages. But its chief, if not its only legitimate, bearing
upon the question must have. depended upon its tendency to
rebut the inference of malice, and so far as it had any such
tendency it was for that very reason competent evidence upon
the main issue in the case. It is said, indeed, that good faith
merely is not enough to protect the party from liability for
malicious prosecution in regard toacriminalcharge.® * * *
For it is found in almost every book upon the subject that if
the defendant, however, causelessly did really act in good faith
and without malice in preferring charges, he cannot be made
liable for malicious prosecution. The question of malice is al-
ways one of intent and open to the jury in this class of cases,
but it’is not so in an action of slander. The law then implies
malice and will not allow it to be rebutted by general evi-
dence, but only by specific proof which the law declares a jus-
tification or excuse as the truth of the words, or that they were
*1 Phil. evid., 115; Rodgwize v. Tadmire, 2 Esp. cases 720,
® Hall v. Suydam, 6 Barber 83,
MALICIOUS PROSECUTION. 141
spoken confidentially and upon a justifiable occasion., So to
in regard to probable cause, the fact being admitted or proved
without controversy it becomes a mere question of law to be
determined by the court, and for this purpose the same proof
is required in all cases. It is not enough to show that the
cases appeared sufficient to this particular, but it must be suf
ficient to induce a sober, sensible and discreet person to act
upon it or it must fail as a justification for the proceeding
upon general grounds. But upon the question of malice the
law is more tender towards the inexperienced or the infirmi-
ties or the idiosyncrasies of the parties, and whatever fairly
tends to show that he acted with good faith and without
malice must be received. There is no necessary or even
natural connection between probable cause and want of malice.
One may and often does act with malice when there is a proba-
ble cause, or may act without malice where there is no propa-
ble cause shown, but in neither of these cases is he liable to
this action. Want of probable cause and malice must concur
to make the party liable.® It is true the want of probable
cause need not be shown to extend to all the particulars
charged, nor is any defense that there was probable cause for a’
part of the prosecution.’ * %* > But the importance of the
question in this case will justify a more extended‘examination |
of the case upon the subject and a more minute discussion of
the principles involved! * * * And it seems to be ad-
§ Turner v. Ambler, 10 Q. B 252.
" Ellis v. Abraham, 8 Q. B. 709; Reed v. Taylor, 4 Taunt, 615.
. }! The history of the common law in regard to this action is well stated
in the elaborate note of Messrs. Hare and Wallace to Munns v. Dupont,
2 Was. C. C. 31-34; 1 Am. leading cases, 200. The law is defined in Far-
mer v. Dowling, 4 Barrows 1971-1974, where all the judges agree that to
maintain an action malice (either expressed or implied) and want of
- probable cause must concur. The case of Johnson v. Sutton, 1 Tenn.
510, S. C.1 Tenn 493, 1 Browns P. C. 76, is also a most important and
satisfactory case, maintaining the general view above stated.
142 LAW OF DAMAGES.
mitted in all the cases where the question has arisen that the
proof of a want of probable cause is not sufficient alone to
maintain the action, provided the defendant can satisfy the
jury that in his conduct he acted in good faith and without
malice, which is much the same thing as applied to this sub-
ject. For although the word malice in popular language is
often used to indicate anger or vindictiveness, in law it is held
to impart nothing more than bad faith, and applied to the
subject of malicious prosecution the want of sincere belief of
the plaintiffs guilt of the crime for which the prosecution
was instituted. The difterence then between the proof of
probable cause and of malice consists chiefly in this that pro-
bable cause has reference to the common standard of human
jadgment of the defendant in particular acts charged as a
malicious prosecution. If the defendant-can show that he had
probable cause for his conduct, that is from such information
as would induce a reasonable and prudent person to believe
the plaintiff guilty ofa crime, he instituted the prosecution, he
is not liable, whatever may have been his own personal
malice for setting it on foot. Probable cause in this sense is a
defense to the action without regard tomotives. To this point
he must show that he was told or knew of the existence of
specific facts which either would constitute crime, or which,
upon competent advice he supposed would constitute crime.
* * * Butifa party fail to show such ground of action as
would have induced a prudent and careful man to have be-
lieved in the plaintiff’s guilt and to have instituted the prose-
cution, he may, neverthelss, if he chooses, claim that in fact he
did act upon what he at the time regarded as good cause, either
from common report, or remote circumstances such as excited °
suspicion in his mind to the extent of creating belief of guilt,
although short of probable cause. If this were not so, the
want of probable cause and malice would be equivalent terms
* French v. Smith, 4 Vt. 363.
MALICIOUS PROSECUTYON. 143
which the case shows they are not. The only distinction
which can be supposed to exist in regard to them is that one
is general and the other is particular—one has reference to the
common standard and the other to the mind and motive of the
defendant. But how can the mind be reached without receiv-
ing proof of every fact which exists, and which may be pre-
sumed to have influenced the conduct of the defendant. If
the subject res integra, I should certainly regard the common
repute both of the plaintifi’s general bad character and of his
being guilty of the particular offense good evidence of probable
cause. Upon principle it should so be held. But in regard to
common report of guilt of the particular offense, we are not
prepared to say that the decision justifies us in regarding it as
evidence of probable cause. General reputation of guilt in re-
gard to the particular offense may not be sufficient ground in
itself for instituting proceedings against one in regard to a
critainal offense, but in doubtful cases where the testimony is
conflicting, and especially it is expected to be drawn from
those in confidence or under the influence of the party accused,
and where consequently there is a difficulty of learning the
full extent of the testimony which can be obtained, until the
witness are put upon giving testimony and where, of course, a
preliminary inquiry is often justified, partly upon suspicion
as an experiment, it is no doubt undeniable that the general
belief in the guilt of the accused in regard to the particular
offense will influence almost any one in deciding upon the
propriety of instituting the prosecution. It ig, therefore, upon
principles I think admissible as a part of the ground consti-
tuting probable cause, and is, as we have before said, in point
of character equivalent to hearsay or the declaration of a third
person in regard to the guilt of the plaintiff which seems to be
admitted everywhere in this class of cases. * * * But,
notwithstanding the satisfactory basis upon which the propo-
§ French v. Smith, supra.
144 LAW OF DAMAGES.
sition seems to rest that this evidence of common reputation
in regard to the particular offense is upon general principles
admissible, among other things, to show probable cause even
and especially to rebut the inference of malice in the defen-
dant, the decisions do not show that such proof has been re-
ceived or offered. This may have resulted from two reasons.
That the same kind of evidence is! attainable by showing a
general bad reputation of the plaintiff at the time of the pros-
ecution, and also that we do not always distinguish between
the class of proof which is admissible in this action, when the
issue is in regard to the suspicion of guilt and probable cause,
to believe one guilty and proof of the very fact of guilt. The
general rule undoubtedly is that general reputation of guilt in
regard to a particular offense is not admissable to prove the
fact of guilt and never, unless it be upon the question of dam-
ages, in regard to reputation in ordinary actions. Hence, it is
natural to throw this cause of action for malicious prosecution
into the general class. These two grounds may account for
this kind of proof not having been offered. Prudent counsel
do not often desire to offer testimony in one form when its ad-
missability is questionable, ifthere is a safe ground upon which
it is clearly admissable. It may not, therefore, be improper to
decide this point. But ifit were necessary, we must certainly
make the proof admissable. This brings us to the question of
the admissability of evidence of the general reputation of the
plaintiff at the time of the instituting of the prosecution in
regard to whether he would be easily induced into the commis-
sion of a similar offense, for this is the view in which charac-
_ter has any proper bearing in regard to crime, if the offense
is one of outrage and violence, whether the accused is com-
monly reputed a peaceable, quite and orderly behaved citizen
or a noisy and boisterous one. And if on the other hand the
offense is one involving fraud, collusion, dishonesty and a
secret practice, whether the man is of a fair, frank, honest and
out-spoken character, or the contrary, some of the case go to
MALICIOUS PROSECUTION. 145
exclude all evidence of this kind‘ * * * But it seems to
us there can be no doubt to this extent., It is admissable upon
the strictest principles for the purpose of showing probable
cause. It is precisely that kind of proof which the accused
might show in his own defense, and its absence must weigh,
more or less, against him in regard to the very offense for
which the prosecution was instituted. To say then that the
prosecutor, in calculating the reasonable and probable ground
of instituting a prosecution for crime, is not to take into ac-
count one of the very elements of defense, and in one event of
prosecution also, is simply absurd. It is a proposition ad-
mitting of no question whatever, and which never could have
been made a question had its proper application to the subject
in view just alluded to been fully appreciated.”®
178. Malice and a Want of Probable Cause Must be Shown.
While the authorities seem to be somewhat confused in regard
to the necessity of the plaintiff proving malice and want of
probable cause, we think that it may be laid down as a general
rule that the plaintiff cannot recover unless he proves that
the prosecution was instituted maliciously and without proba-
ble cause.®
* Newsam v. Carr, 2 Stark cases 69.
5 31 Vt. 189; see Bacon v. Towne, 4 Cush. 217; Rodsiquez v. Tadmire,
Esp. 721; Wood v. U. S. 6 Peter 342-366; 2 Greenleaf evid , 8. 458; Wil-
liams v. Taylor, 6 Bing. 183; Mitchell v. Jenks, 5 B. and Ad. 588, Mit-
chell vy. Williams, 11 M. and W. 205. ‘The text writers lay it down as a
settled practice upon this point that the question of malice in the defen-
dant’s mind in doing the act isa distinct issue in the action, and what-
ever tends to prove or disprove it is competent to be rescinded.” 2
Greenleaf on evid., Sect. 453.
§ Arnmerman v. Crosley, 26 Ind. 451; Newell v. Downs, 8 Blackf. 523;
Wilkinson v. Arnold, 11 Ind. 45; Seeger v. Pfifer, 35 Ind.13; 1 Hill on
Torts, 217, S. 22; 2 Greenleaf on evid., 8. 453; Farmer v. Darling, 4 Burr
1971; Stone v. Crocker, 24 Pick. 81-83.
146 LAW OF DAMAGES.
179. Distinction between Malicious Prosecution and False Im-
prisonment. Courts and law writers have some times been
much puzzled in drawing the line of distinction between
malicious prosecution and false imprisonment, but it has
finally been established, and the distinction between malicious
prosecution and false imprisonment is now pretty well settled.
“When the arrest is upon valid process issued by a court hav-
ing jurisdiction, trespass for false imprisonment will not lie,
though such arrest is maliciously procured by the prosecutor
without probable cause.6 False imprisonment, more especially
in civil action, is some times termed in legal language
malicious arrests, and an action for this precised form of in-
jury: requires substantially the same allegation and proof of
malice and want of probable cause as the action for malicious
prosecution.””
180. What the Plaintiff Must Prove in Order to Sustain His
Case. The plaintiff must, in order to maintain his action,
show: 1. That he has been prosecuted by the defendant
either criminally or ina civil action, and the prosecution is at
an end.’ If he can show by the record or a duly certified copy
thereof that there was a finding and judgment for him in a
civil suit, this will be sufficient, or if he can show that there
was arule “to discontinue on payment of costs and that the
costs were taxed and paid, without proof of a judgment or pro-
® Bell v. Graham, 1 Nott and M. Mc. 278; Hail vs. Suydam, 6 Barber
8. 8. R. 83; McLaine v. Bank. of Cumberland, 9 L. R. 82.
"1 Hill on Torts, 217 S. 22;8Stancliff v. Palmer, 18 Ind. 321; 1 Common-
wealth v. Snelling, 15 Pick. 321-330; Stokely v. Harding, 8 C. and P. 11;
Mitchell v Jenks, 7 B. and Ad. 588-594, 2 Greenleaf on evid., S. 1532;
Barnes v: Cress, 2559 Met R. 93, Burrill’s law dict.
1 2 Greenleaf evid., S. 449; Reed v. Taylor, 4 Taunt 516; Wood v. Buck-
ly, 4 co. 14; Pierce v. Thompson, 6 Pick. 193; Stone v. Crocker, 24 Pick:
81; Sharp v. Pichel, 30 Ind. 457.
MALICIOUS PROSECUTION. 147
duction of the record,’ but an order to stay proceedings, is not
sufficient.”* What will be considered in law the ending of
the prosecution, the authorities are not in harmony upon.
But we think that if the plaintiff can show a trial and finding
for him either in a criminal or civil case, or in case of a crimi-
nal prosecution that the indictment or information has been
quashed, or that a nolle prosequi has been entered, it will be
sufficient. Professor Greenleaf, in his work on evidence, says
that “it must appear that the plaintiff was acquitted of the
charge; it is not enough that the indictment was ended by
the entry of nolle prosequi.” But the most recent decisions
hold that if the plaintiff can show that the original prosecu-
tion is at an end, it is sufficient. And that if the record shows
that the suit that the defendant instituted has been disposed
of by the court in such a way that no process or proceeding
can be had against the plaintiff without commencing a new
action, that it will bea sufficient ending of the suit to authorize
a recovery. If this was not so men might be subject to the
most wanton outrages and oppression without any remedy
whatever, for when a man is maliciously indicted he may not
be able to obtain a trial on the merits, if the prosecuting attor-
ney is determined to and actually does nolle pros the indict-
ment or the information. If, therefore, the plaintiff can show
on the trial that he was arraigned and tried before a magis-
trate who was authorized only to hear his case and bind him
over, and that he was acquitted by such a magistrate, or that
the information or indictment has been quashed or a noile pros
entered, or that his case has been discontinued, or that he was
tried in a court of competent jurisdiction on the merits and
2 Chapman v Wood, 6 Black (Ind.) 604.
? Chapman v. Wood, 6 Black.(Ind.) 514; Weeks v. Fentham, 4 T. R.
247; Fisher v. Bristow, 1 Douglas 215; Hays v. Blizzard, 30 Ind. 457;
Sayles v. Biggs, 4 Met. 421.
148 LAW OF DAMAGES.
was acquitted, it will be a sufficient showing of the termina-
tion of the prosecution as will entitle him to recover.’
2. He Must Show that the Prosecution was Instituted Maliciously
and Without Probable Cause. The plaintiff must, in order to re-
cover, establish by the evidence the material allegation of his
coinplaint. One of the elements that enters into a case of
malicious prosecution is that of malice, and unless the plaintiff
alleges in his complaint and establishes on the trial that the
prosecution was maliciously commenced, he cannot recover.’
Malice may be inferred from want of probable cause, but not
necessarily so. Anything done willfully and purposely to the
injury of another in a legal sense is done maliciously.’ The
plaintiff may, for the purpose of showing malice, show the de-
fendant’s conduct during the transaction, his declaration in re-
gard to the subject, and all his acts in exposing the plaintiff
by publication or otherwise.’
3. The Onus is on the Plaintiff to Show Affirmatively by Circum-
stances or Otherwise that the Defendant had no Ground for the Prosecu-
* See authorities above. But the appellant insists that the evidence
does not show a final determination of the prosecution complained of
and the discharge of the appellant therefrom. It is true no record evi-
dence was shown of a final discharge of the appellee, but his arrest for
larceny and imprisonment at the instance of the appellant are shown,
and that the appellee appeared before the mayor in obedience to the
writ; that no prosecuting witness appearing the case was continued; that
he appeared again, according to the continuance; that still no witness
appeared against him and no trial was had, but that he was allowed to
go at liberty, allof which was shown by parol without objection and
which stands uncontradicted. We think this is sufficient to authorize
the jury to find that the prosecution was at an end. Leener v. Hamill,
57 Ind. 433.
5 2 Greenleaf on evid., Sect. 453.
® Commonwealth v. Snelling, 15 Pick. 321; Stokely v. Hamridge, 8 C-
and P. 11.
71 Hill on Torts, p. 421; Mitchell v. Jenkins, 5B. and Ad. 504; Wheeler
v. Nesbett, 24 How. U. 8. 552.
MALICIOUS PROSECUTION. 149
tion. No such reasonable ground of suspicion sufficiently
strong in itself to warrant a cautious man in believing that
the person arrested is guilty of the offense with which he is
charged.’ What these circumstances may be cannot be speci-
fied or named with any degree of certainty, but it has been re-
cently held that the plaintiff, for the purpose of showing a
want of probable cause and that the defendant had no grounds
for his prosecution, may show that prior to the commence-
ment of the suit that he was a man of good character, and that
the defendant when he commenced his prosecution was fully
apprised of that fact. The court, in commenting upon the
case, says: “As the onus of proving a negative—the absence
of probable cause—is thrown upon the plaintiff, slight evi-
dence will usually suffice for such purpose. But the evi-
dence of a uniform good character up to the time of the charge
is something more than slight evidence, and the plaintiff
should have the benefit of it. If known to the prosecutor
what single fact is better calculated to weaken a belief, he be-
ing a prudent man, in the guilt of a suspected party. On the
other hand his bad character may be shown by-the defense as
good ground for augmenting suspicion against him.”*
3. That he has been damaged by reason of the prosecu-
tion. The amount of damages that the plaintiff ought to re/
cover is left to a very great extent to the judgment of a jury
under the instruction of the court.’ e
1 Blizzard v. Hays, 46 Ind, 166.
1 Blizzard v. Hays, 46 Ind. 160; Jacks v. Stimpson, 13 IN. 701; Richy v.
McBean, 17 Il. 63; Hurd v. Shaw, 20 Ill. 456; Galaway v. Stewart, 49
Ind. 156.
It must clearly appear that the prosecution was groundless, and that
it was so known or might have been known to the prosecutor. Kirk-
patrick v. Kirkpatrick, 39 Pa. st. 288.
2 2 Greenleaf on evid., Sect. 436.
,
150 LAW OF DAMAGES.
181. A Full Defense. The defendant may defeat the plain-
tiff’s recovery by showing that he never instituted the prose-
cution complained of, or that the cause of action is barred by
the statute of limitation, or that there was a want of malice, or
that he had a probable cause for commencing the prosecution.*
182. Elements of Damages. The jury in assessing the plain-
tiff’s damages should take into consideration: 1. The peril
occasioned to him in regard to his life or liberty. 2. The in-
. jury to his reputation. 3. Injury to his feelings. 4. Injury
to his person. 5. All necessary expenses which he has been
subject to on account of the prosecution, including attorney’s
fees.’
183. The Damages. The measure of damages in cases of
this kind is full compensation to the plaintiff for all losses sus-
tained, including injury to his reputation, feeling and person,
* Stull vy. Howard, 26 Ind. 451; Newell v. Downs, 8 Black (Ind.) 523;
Wilkinson v. Arnold, 11 Ind. 45; McKowen y. Hunter, 30 N Y. 625;
Barron vy. Mason, 31 Vt. 189; McLane v. Birdson, 24 Ga. 265; Lyon v.
Hancock, 35 Cal. 625; White v. Tucker, 16 Ohio st. 468; Goggons v. Mes-
more, 31 Ga. 331; 2 Greenleaf on evid., 8. 457; Sandback v. Thomas, 1
Stark 306; Gould v. Barrett, 2 M. and Rob 171; Doe v. Davis, 1 Esp 358;
Noell v. Rook, 7 B. and C. 404. A verdict of guilt in a criminal prosecu-
tion founded upon correct legal instructions, is conclusive evidence of
probable cause in a subsequent action for malicious prosecution, al-
though such a verdict was set aside for newly discovered evidence.
Parke v. Farly, 10 Cush. 279; Parke v. Hunt, 2 Guy 125, Bibbs 286.
2 2 Greenleaf, S. 456; Zigler v. Powell; 54 Ind. 173; Field on dam , Sect.
687; Thompson v. Mussey, 3 Greenleaf 305; Tripp v. Thomas, 3 B. and
C. 427; Sandback v. Thomas, 1 Stark 306; Gould v. Bennett, 2 M. and R.
171; Doe v. Davis, 1 Esp. 158; Sancleve v. Eland, 4 Taunt 7; Webb v.
Nichols, R. and C 417; Closson v. Stapple, 42 Vt 209; Sears v, Hatha-
way, 12 Cal. 277; Talley v. Corsie, 16 L. T. (N. C.) 796; Kidred v. Stilt, 51
IL 401; 2 Addison on Torts, 767; Saul v. Roberts, 1 Ld. R. 378; Chapman
v. Pickersville, 2 Will 145; Sheldon v. Carpenter, 4 N. Y.578; Mayne on
dam. 259; Goldsmith v. Picard, 27 Ala. 142; Donnell v. Jones, 13 Ala. 490;
Field on dam., 8. 549.
MALICIOUS PROSECUTION. ibt
and peril to his life and liberty, all necessary expenses in-
curred in defense of the original suit, including attorney’s fees,
and some times in aggravated cases the jury are permitted to
assess exemplary damages.
184. Circumstances in Mitigation. The defendant may show
in mitigation of damages all the suspicious circumstances go-
ing to establish the plaintiff's guilt. There is some conflict
among the authorities as to whether the defendant can attack
the plaintiffs character for the purpose of reducing the amount
of his recovery. But it may now be considered pretty well
settled by the weight of authority in this country that the
plaintiff is entitled to damages for injury to his reputation,
and that, therefore, the value of that reputation is in issue and
must be fixed by the jury in making up their verdict, and
that evidence is admissible not only to rebut the presumption
of malice and want of probable cause, but also in mitigation of
damages. The English authorities hold that the plaintiff
cannot recover damages for injury to his reputation unless it
is expressly alleged in the complaint.’
3 Zigler vy. Powell, 54 Ind. 173; Field on law of damages, S. 687; same
445; Sheldon v. Carpenter, 4 N. Y. 578; Israel v. Brooks, 23 Ill. 575; Mar-
tin v. Hardesty, 27 Ala. 458; Downy v. Burch, 2 M. & R. 374; Smith v
Hyderman, 10 Cush. 554; Mayne on dam., 261; Goodrich v. Warner, 21
Conn. 432; Beal v. Robinson, 8Ind 276; Bacon v. Town, 4 Cush. 217;
Fitzgibbon v. Brown, 43 Peter 342; 2 Greenleaf evid., 458; James v.
Phelps, 11 Add. & El. 483; Sears v. Hathaway, 2 Cal. 277; Wheeler v.
Nesbet, 24 Hom. 548; Cooper v. Watson, 50 Me. 80; Add. on Torts, 767.
4 Israel v. Brooks, 23 111. 575; Martin v. Hardesty, 27 Ala. 458; Downy
v. Burch, 2 M. & R. 374; Smith v. Hyderman, 10 Cush. 554; Mayne on
dam., 261; Goodrich y. Warner, 21 Conn. 432; 2 Greenleaf evid., 8. 458;
James v. Phelps, 11 Add. & El. 483; Sears v. Hathaway, 2 Cal. 277;
Newell v. Downs, 8 Black 523; Long v. Rodgers, 19 Ala. 327; Wheeler v.
Nesbet, 24 How. 545; Cooper v. Watson, 51 Me. 81.
5 Addison on Torts, 767; Rodridz v. Tadmin, 2 M. & Rob. 374; Newson
v. Carr, 2 Stark 70.
159 LAW OF DAMAGES,
185. The Power of the Jury. In cases of this character, as
well as all others which are brought to recover damages for in-
jured feeling, reputation or character, the jury is allowed a
wide discretionary power. They must determine the want of
probable cause and of malice from all circumstances surround-
ing the case. They may infer malice from a want of probable
cause, but are not compelled to do so. They can have no
means of arriving at the actual damages the plaintiff has sus-
tained in injury to his feelings and reputation, and at best
their verdict for damages of this character is not much more
than a conjecture.®
186. Liability of Corporation for Malicious Prosecution. The
authorities are very much in conflict as to the liability of a
corporation for malicious prosecution. But there is a strong
tendency to hold a corporation liable to the same extent for an
injury done by its servant in the course of his employment as
an individual is held. And we think that the weight of
authority upholds the doctrine that corporations are responsi-
ble for malicious prosecutions."
6 Newell v. Downs, 8 Blackford, 523; Long v. Rodgers, 19 Ala 327;
Wheeler v. Nesbet, 24 How, 545; Cooper v. Waldron, 50 Me. 80; Smith v.
Hyderman, 10 Cush. 554; Field on damages, S. 689.
™ Copley v. Grover & Baker Sewing Machine Co., 2 Wood, U. 8S. d.
Rep. for La, p. 494; 97 Common Bench 290;1, P. & C. R. W. Co. v. An-
thony, 43 Ind. 183; First Baptist Church yv. Schenectady & Troy R. R.
Co., 5 Barb. (N. Y.) 197; Vinas vy. Merchants’ Mett. Ins. Co., 27 La. 367;
Wheeler v. Q. National Bank, 57 Tenn. 469; Vance v. Erie R R Co.} 32
N. Y. 334; Fenton v. Wilson Sewing Machine Co, 9 Philadelphia Rep.
189; Goods v. East Haddan Bank, 22 Conn. 530; Opposit Gillett v. the
Missouri Valley R. R. Co. v. 55 Mo. 315; 17 Am. Rep. 653; 37 Ala 560.
‘
CHAPTER X.
NUISANCE.
A Nutsance DEFINED. PrRivaTE AND Pusiic. REMEDIES.
THE RIGHT OF AN INDIVIDUAL TO ABATE A NUISANCE. A
PARTY WHO MAINTAINS A NUISANCE LIABLE IN DAMAGES,
THE MEASURE OF DAMAGES, PENNSYLVANIA Court. In-
DIANA SUPREME COURT. DANGEROUS ANIMALS RUNNING
AT LARGE A NUISANCE. FEROCIOUS DOGS A NUISANCE.
WHEN.
187. 4 Nuisance Defined. A nuisance, in its largest, most
comprehensive sense, signifies anything that worketh hurt,
inconvenience or damage.’
\
188. Two Kinds of Nuisances. There are two kinds of nui-
sances, public and private.’ A public nuisance is one that'an- ~
noys all the membersofthe community. A private nuisance is
something that injuriously affects the land, tenement or heredi-
13 Blackstone com, 215; State v. Berthol, 6 Black. (Ind.) 474.
22 Greenleaf on evid., 465, Call v. Buttrick, 4 Cush, 345; Kearny v.
Farrell, 28 Conn., 317.
154 LAW OF DAMAGES.
tament of an individual.? Thus it has been held that any act
done by another from without which renders the enjoyment
of life within a house uncomfortable, whether it is produced
by infecting the air with noisome smells, or with gases injuri-
ous to health isa nuisance* A construction of any kind on
one’s own land, which, of itself, or by its use, directly injures
a neighbor is a nuisance.®
189. The Remedies, A party affected by a private nuisance
“has, as a general rule, one of two remedies: 1. He may abate
it withhis own hands. 2. He may sue to recover damages and
have it abated by order of a court of competent jurisdiction.’
We will notice these remedies in their order.
190. The Right of an Individual to Abatea Nuisance. Therights
of an individual vary as the circumstances around him change.
Asa general rule one individual has no right to enter upon the
land of another without his permission and remove or injure
his property in any way. , But this rule is based on the suppo-
sition that every man will use his property in such a way as
‘not to interfere with the rights of others.
3 Grady v. Walmer, 46 Ala., 382; 2 Greenleaf on evid., s. 465.
‘McKeon vy. Lee, 51 N.Y. 300; Grady v. Walmer, 46 Ala., 381; 2
Greenleaf, s. 468.
* Where one carries on the business of finishing steam boilers in the
compact part of a city, whereby the occupant of an adjoining dwelling
was annoyed by noise and dust, that such occupant might maintain an
action for damages against the manufacturer. The manufacturing of
steam engine boilers is a lawful business, yet if it is carried on in such
a manner as to make a great annoyance to others, the injured party is
entitled to redress in damages. Fish v. Doge, 4 Denio, 311; McKeon v.
Lee, 51 N. Y. 300.
T Addson on Torts, 234.
11 Addson on Torts, 234. Norris y. Baker, 1 Rall R. 393.
In an action for a nuisance to a messuage dwelling house and premises,
caused by noxious vapors, proceeding from a smelting works upon lands
NUISANCE. 155
Hence, if one so uses his land or other property on his
premises in such a manner as necessarily tends to injure the
property of another, he is liable to that other for any injury
which may result from such use without regard to the care and
skill exercised in the use of the property’ and the injured par-
ty may, under certain circumstances enter the premises and
abate the nuisance. The law, however, is jealous of its pre-
rogatives and seldom commissions one to exercise such power.
But where an individual is in imminent danger of receiving
great injury either to person or property, the law will justify
him in resorting to such a summary remedy, and he can use
just such force as is necessary to prevent the threatened in-
jury?
191. A Party will only be Liable in Removing a Nuisance for Un-
necessary Injury. In abating a nuisance a party will only be re-
of the defendant, to which they pleaded the general issued the juge di-
rected the jury that every man is bound to use his own property in such
a manner as not to injure the property of bis neighbor unless by the
lapse of certain periods of time he has acquired a prescriptive right to
do so. But the law does not regard trifling inconveniences. Everything
must be looked at from a reasonable point of view, and therefore in an
action for a nuisance to property by noxious vapor, arising on the land
of another, the injury, to be actionable must be such as to visibly dimin-
ish the value of the property, and the comfort and enjoyment of it.
Thatin determining the question, the time, locality and all the circum-
stances should be taken into consideration, that in countries where
great works have been erected and carried on, which are the means of
developing the national wealth, persons must not stand on extreme
rights and bring actions in respect,to every matter of annoyance. If
that were so business could not be carried on in those places. Held no
misdirection. St. Helena Smelting Co. v. Tipping, 4 B. & S., 408—6,016
Exch. cham. and 11 Jur. N. 8. 785. House of Lords, Bamford v. Tur-
ley, 3B. & S. 66, 8. c. 9 Jur. N.S. 377.
2 Rex v. Roswell, 2 Salk, 459; Miller v. Burch; 32 Texas, 208; Ely v.
Supervisor Co., 36 N. Y., 297; Barclay v. Commonwealth, 23 Pa. st., 503.
3 Graves v. Shattuck, 35 N. H., 257.
The party abating a nuisance ‘is only liable for a wanton and unnec-
essaryinjury. 27 Ind. 394,
156 LAW of DAMAGES.
sponsible for wanton and unnecessary injury. But in deter-
mining the question as to whether the defendant in abating
the nuisance committed wanton and unnecessary injury, the
court or jury trying the cause should take into consideration
the kindof property constituting the nuisance and all the at-
tending circumstances.! Thus, where the superintendent of
two of the Erie canals, in making repairs, destroyed a canal
boat belonging to the plaintiff, and suit was brought for dam-
ages, the Court of Appeals of the State of New York, in com-
menting on the question of the liability of the defendant
said: “It was the duty of the defendant, as superintendent of
canal repairs, to keep in repair that section of the canal in-
trusted to him, and to remove obstructions to navigation, and
he claims protection in this case on the ground that he was in
the discharge of his duty, when he cut up the plaintiff’s boat.
He bases his claim to protection upon several grounds, which
T shall proceed to notice: 1. He claims this case comes under
this provision of our statute which provides that whenever the
navigation of any of the canals shall be interrupted or endan-
gered it shall be the duty of the commissioner, without delay,
to repair the injury causing or threatening such interruption
and for that purpose they shall have power, by themselves or
their agents to enter upon and use any contiguous land, and
to procure therefrom all such material as in their judgment
may be necessary or proper to be used in making such repairs.
This section confers an authority on the canal commissioner.
It is their judgment that is to determine the necessity or pro-
priety of entering upon the adjoining lands for the purpose in-
dicated. It confers no authority whatever upon the superin-
tendent. Theymay undoubtedly act, but must be under the
special direction and authority of the commissioner in charge,
whose judgment is to determine the necessity. Here it is not
claimed that the defendant had any direction whatever from
4 Indianapolis v. Miller. 27 Ind. 394.
NUISANCE. 157
the canal commission to take and cut up this ‘boat. * * *
But in this case, if the canalcommission had done the act com-
plained of, instead of the superintendent, he could not have
found protection under the statute, as the act done does not
come within its terms. It is difficult to perceive how it can
well be claimed that a statute which confers authority upon
canal commissionersto enter upon adjoining lands and take
material to repair the canal, justifies the destruction of prop-
erty that might be in the canal. It would not be claimed that
a canal commissioner could take a loaded boat and appropriate
her or her cargo to stop or repair a break in the bank of the
canal. It is clear, therefore, that the statute affords no pro-
tection to the defendant. 2. It is claimed that the canal is
in law a public highway and that this boat was a public nuis
ance in such highway, interrupting navigation, which any
person and certainly a public officer had a right to remove.
It is not alleged in the answer, and it was not found by the
referees, that it was a nuisance. N avigation was interrupted
by the want of water, caused by the breaking not so much by
the boat. This boat was not in the canal in such a way as to.
interfere with the passage of boats. But there should have
been an issue and finding upon this point. If the referee had
found that this boat was a nuisance, the defendant would not
necessarily been justified in destroying it. ‘In removing or
abating nuisance no unnecessary damage or injury to property
can be justified, and the referee might have found still, as he
has found, that: the defendant should have adopted some other
method to restore navigation than the destruction of the boat.
* * * The plaintiff’s boat was valuable private property.
The plaintiff was in no degree in fault, and he did not in any
way. contribute to the break that caused the interruption of
navigation. The duty of the defendant was imperitive to re-
pair the canal, and though the plaintiff's boat was private
property he had a right to destroy it, if such destruction was
necessary to enable him to restore navigation. The right did
158 LAW OF DAMAGES.
not arise simply because it was more convenient to repair the
canal by destroying the boat, nor because this was the cheapest
or speedy way to doit. The destruction of this private prop-
erty should have been the last resort after other reasonable ex-
pedients had failed.”*
192. The Purchaser of Real Property Responsible for the Injury
Received from a Nuisance Erected by His Vendor. The law is well
settled that where a nuisance is erected upon a tract of land
by the owner, and he afterwards sells and conveys the title to
another, and the nuisance is permitted to remain on the land
after the change of possession and a party is injured, he may
maintain his action against the person who erected the nuis-
ance, or the purchaser who suffers it to remain on his land, or
perhaps against them both.* But he can have only one satis-
faction. Each injury the plaintiff receives will be considered
in law a new nuisance and affords a new cause of action.’
Therefore, a purchaser may maintain an action for the con-
tinuance of a nuisance erected before he purchased the realty,
and an heir for the continuance of one erected during the time
of his ancestors. But a private individual can maintain an
action in case of a public nuisance only on account of some
particular special injury, which he sustains from it over and
above what is common to the general public.
5 Hicks v. Dorn, 42 N. Y. 47; Russell v. The Mayor and City of New
York, 2 Denio 475.
® Raswell v. Prio Salk, 460 id. 12, Meade 635; Penoyer v. Sanguman, 8
Mett. 534; Vedder v. Vedder, 1 Denio 257; Body v. Weeks, 3 Barb. 157;
Baugh v. The State, 14 Ind 29.
? Pettis v. Johnson et al. 56 Ind. 189; McCowan .v. Whiteside, 31 Ind.
235; Biglow v. The Hartford Bridge Co , 14 Conn. 565; Grigley v. C. Lake
W.Co., 40 Cal. 390; Field on damages, 605.
The question in the case is, can a private person enjoin the obstruc-
tion of a public highway without showing a special injury to himself
not common to the public? It is claimed that the appellants have a
property in the road which a court of equity is bound to protect against
NUISANCE. 159
193. The Measure of Damages. The plaintiff may recover in
an action for an injury caused by a nuisance, all. the damages
that he has sustained up to the time of the commencement of
his action, but as a general rule no prospective or permanent
injury will be considered.? But if the nuisance is of a perma-
nent character that will continue without change from any
cause but human labor, then the damage is an original dam-
age, and may at once be fully compensated. The rule for the
assessment of damages in case of injury to real property apply
in actions for injuries by a nuisance.’
194. The Supreme Court of Pennsylvania. In the Supreme
Court of Pennsylvania the plaintiff, in the court below,
brought his suit to recover damages occasioned by the defen-
dant throwing tanbark in the Lackwaken creek above the
plaintiffs mill, which, being carried down by said stream, had
been deposited upon the said land and said millpond of the
plaintiff's, thereby filling and obstructing said pond and inter-
fering with the free and beneficial use by the plaintiff of the
water of said creek. In commenting on the measure of dam-
ages the court said: “In general, the rule for the measure of
damages in cases of tort may be said to be that which aims at
actual compensation. There are qualifications, however, in-
the wrong-doer. The appellants have no legal rights that can be en-
forced at law. Willard v. The City of Cambridge, 3 Allen 574. Nor
can a bill in equity in the abatement of a nuisance be maintained.
From an injury common to all, arising from a public nuisance, the —
remedy is by indictment or public prosecution. McCowan v. White-
side, 31 Ind 235; Hartshorn v. Ink 8. Reading, 3 Allen 501; Barnard v.
Conn. River R. R. Co., 7 Cush. 506.
Harvard College v. Stearn, 15 Gray 1.
2 Blunt v. McCormick, 3 Denio 283; Penoyer v. Sanguman, 8 Mett. 534;
Wagner v. Jermain, 3 Denio 306; Pillsbury v. Moore, 44 Me. 154; Thayer
v. Brooks, 17 Ohio 489.
8 Black com 220; Ill. Cen. R. RB. Co. v. Grabill, 50 Ill. 241; Battishell v.
Reed, 18 C. B. 696; Powers v. The City of Council Bluffs, 45 Iowa 410;
Barr v. Hoffman, 79 Pa. st. 71.
160 LAW OF DAMAGES.
advertent or unintentional injuries or acts, unaccompanied
with malice, draw after them only their direct and immediate
consequence, and not those remote of speculation, while gross
negligence or malicious acts may be the subject of larger dam-
ages, but in the latter they rest in the sound discretion of the
jury, uninfluenced by prejudice or passion. Damages for in-
juries to property vary also according to the nature of the
claimant’s rights. The owner of the freehold may undoubtedly
recover for an injury which permanently affects or depreciates
his property, while a tenant or one having only a possessory
right may recover for an injury for his use or enjoyment of it.
vk * & Tf, therefore, a permanent injury was created by the
lodgment of the tanbark in the pool of their dam, which
actually depreciated the property as a water power, it must
affect the price or value of land to which it belongs, and why
should this not be compensated in damages? * * * Com-
‘pensation for diminished enjoyment or use of the property for
a certain number of years, is not compensation for the
diminished value of the estate itself.”
194. Supreme Court of Indiana. In a recent case the Su-
preme Court of Indiana held when the plaintiff had obstructed
one of the streets of Indianapolis by piling a large amount of
sand and gravel thereon and was notified to remove the same,
but neglected and refused to do so, the city authorities removed
the sand and scattered it on the streets at an expense of two
hundred dollars. Suit was brought against the city to recover
the value of the sand; that in settling the question of damages
that it was proper to take into consideration the value of the
sand and gravel, its condition on the street, the costs of re-
moval, the benefit of the plaintiff himself in having it placed
" Seeley v. Alden, 61 Penn. st. 302; see Repka y. Sergeant, 7 W. & 8. 9;
Schredele v. Koehler, 4 Carey 181; Robb v, M., 1 Jones 305,
NUISANCE. 161
on the street bordering on his own premises, the convenience
or inconvenience of its removal to the lot of the plaintiff, and
the costs thereof compared with the value of it, and if from
the facts it was made to appear that there was no unnecessary
injury that the plaintiff could not recover.'
195. tis a Nuisance to Let Dangerous Animals Run at Large.
The law is well settled that a man has no right to suffer torun
at large animals of a fierce nature, such as lions, tigers, etc.,
and he will be held responsible for all injury that may be com-
mitted by such animals without notice of their vicious pro-
pensities.' But in case of a domestic animal not naturally
inclined to commit mischief.as cows, oxen and the like, the
owner is not liable for any injury committed by them against
a person or personal property, unless he had previous notice of
their mischievous propensities, or that the injury is attributed
to his negligence.” But he is bound at his peril to take notice
of their natural and notorious disposition to rove, and he is
bound to confine them on his own land, and if they escape and
commit a trespass on the land of another the owner will be
held responsible, although he had no notice of the fact.’ Re-
cently the Supreme Court of California, in a case where suit
was brought by the plaintiff to recover damages for injury re-
! City of Indianapolis v. Miller, 27 Ind. 394. :
A city has no power to authorize the construction of anything which,
when constructed, will be a public nuisance. Pettis v. Johnson, 56 Ind.
139; the Terre Haute Gas Co. v. Teel, 20 Ind. 131.
1 Rex v Huggens, 2 Ld. Raym. 1583; Jenks v. Turner, 1 ib. 110; Mason
v. Keeling, 1 ib. 608; Scribner v. Kelly, 38 Barb. 14; Brozzi vy. Harris. 1
F. & F. 92; Lauerone v. Mangiaute, 41 Cal. 138.
” Page v. Hollingsworth, 7 Ind. 317; 1 Chitty Plea, 82-93; Vrooman v.
Lawyer, 13 Johns 339; Lauerone v. Mangiante, 41 Cal. supra.; Woolf v.
Chalker, 31 Conn. 131; Buckly v. Lenard, 4 Denio 500.
5 Page v. Hollingsworth, supra.; Williams v. New Albany R. Co.,5
Ind, I11; Lafayette R. R Co. v. Shriner, 6 Ind, 141,
162 LAW OF DAMAGES.
ceived from being bitten by a dog, says: “It is insisted on
behalf of the defendant that a person may lawfully keep a
ferocious dog, one that is accustomed to bite mankind. That
position may be true, and it may also be conceded that he has
the same right to keep a tiger. The danger to mankind. and
the injury, if any suffered, comes from the same source—the
ferocity of the animal. In determining the responsibility of
the keeper for an injury inflicted by either animal, the only
difference I can see between the two cases is that in case of an
injury caused by a dog the knowledge of the keeper must be
alleged and proven, for all dogs are not ferocious, while in the
case of a tiger such knowledge will be presumed from the
nature of the animal. The knowledge, however, established,
whether by evidence or by presumption, is the same in sub-
stance and works the same result. When the facts in two or
more cases are alike the law will pronounce similar judgments.
It will not be doubted that for any injury inflicted by a tiger
his owner will be responsible, and, in my opinion, there is as
little to doubt that the owner of a dog which he knows to be
ferocious is equally liable for similar injuries occasioned by it.
In either case the owner, knowing the vicious propensitie
and ferocious nature of the animal, keeps it at his own risk,
and he should bear the responsibility of the injury inflicted by
it upon a person who is free from fault.’*
196. Ferocious Dog. As has already been intimated, the
keeper of a ferocious dog that is inclined to bite mankind or
attack and injure other domestic animals, will be held
responsible for such injury, provided he had previous no-
tice of his ferocious disposition.® There is no rule of law that
4 Lauerone v. Mangiante, 41 Cal. 188; Bozzi v. Harris, 1 Fost & F. 92;
May v. Burdette, 92 B. 101. :
5 Vrooman v. Lawyer, 13 John 339; Fairchild v. Bently, 830: Barb. 147;
Woolf vy. Chalker, 31 Conn. 131; Fleming v. Orr, 29 Eng. L. & E. 16;
Steel v. Smith, 3 E. D. Sinith 321; Cox v. Burbridge, 13 G. B. N. 8. 430.
NUISANCE. 163
requires proof of any particular number of instances of unpro-
voked biting in order to charge the owner with notice of his
mischievous and ferocious. disposition. If the plaintiff can
show by sufficient evidence of a single instance of biting it
will be sufficient. A dog that is accustomed to bite is con-
sidered a common nuisance, and if suffered to run at large un-
muzzled any person may kill him, whether he is doing or at-
tempting to do mischief or not.’
And where the inhabitants of a dwelling house are con-
tantly annoyed day and night by the barking of a dog of an-
other to such an extent as to disturb the family, the inmates
may kill the dog if he cannot be otherwise prevented from an-
noying them.! Any person may kill a mad dog or a dog which
he has reason to believe has been bitten by a mad dog, or a dog
he has reason to believe is mad.” (For the assessment of dam-
ages see anti-page 286.) In case of the entire destruction of
personal property, the measure of damages is the value of the
property at the time of the destruction, and in some cases in-
terest on the value has been allowed.’ But in case of the in-
jury to.property not resulting in destruction, the measure of
damages is the difterence in the value of the property with the
injury and its value before the injury, the value of the use of
-it, and in cases of animals the cost of medical attention.*
6 25 Conn. 92; 11 Ind. 1 N. C.
? Putnam v. Payne, 13 Johns R..312; see also 9 Johns R. 233.
1 Brill & Brill v. Flagler, 23 Wend. 353; Wright v. Ramscot, 1 Saund.
84; 17 Barb. 561; 13 Allen Pract. 167; 24 How. Pract. 481; 26 Vt. 638.
231 Conn. 121; 13 Johnson 312.
3 Gillett v. West R.-R. Co., 8 Allen 560; 34 Mo. 469; I. C. R. RB, Co. v.
Finnegan, 21 Ill. 648; Shelbyville L. B. R. R Co v. Lemark, 4 Ind, 471.
4 Shelbyville L. B. R. R. Co. v. Lemark, 4 Ind. 471, N. H. 8. Co. v.
Vanderbilt, 16 Conn. 420; Williamson v. Barrett, 13 How. 101. But to
recover special damages it must be alleged in the complaint. Tegorden
v. Hatfield, 11 Ind. 522.
164 LAW OF DAMAGES.
198. The Owner of Land Cannot Encroach on His Neighbors.
The right of one land owner to take down his building and ex-
cavate the soil, is regulated by the rules of the common law.
One cannot, by altering the condition of his land, deprive the
owner of thé adjoining land of the privilege of using his own
as he might have done before. Thus he cannot by building a
house near the margin of his land prevent his neighbor from
excavating, although it may endanger the house, nor from
building on his own land, although it may obstruct windows,
unless, indeed, by lapse of time or by expressed grant the ad-
joining land has become subject to a right of servitude.? But
a distinction is made between an injury to a house and other
buildings and an injury to thesoil. Where an adjoining owner
so excavates the dirt from his own land as to withdraw the
natural support of his neighbor’s soil, he is liable for damages,
and an injunction may be had to prevent him performing the
threatened injury, provided the owner of the land has not, by
building, increased lateral pressure upon the adjoining soil.
“Tt is in consequence from this principle that for the injury to
his soil, resulting from the removal of the natural support to
which it is entitled by means of excavation on an adjoining
tract, the owner has a legal remedy in an action at law against
the party by whom the work has been done and the mischief
thereby occasioned. This does not depend upon negligence or
unskillfulness, but tipon a violation of a right of property
which has been invaded and disturbed. But this unqualified
rule is limited to injuries caused to the land itself, and does
not afford relief for damages by the same means to artificial
structures. For an injury to a building which is unavoidable,
incident to the depression or slide on which it ‘stands, caused
by the excavation of a pit on adjoining’ land, an action can
only be maintained where a want of due care or skill, or posi-
tive negligence, has contributed to produce it.” Where an in-
? Smith y. Kimrich, 7 Conn, B. 565-566; Durant v. Palmer, 5 Dutch, 544.
NUISANCE. 165
jury of this kind is produced, the plaintiff can recover for all in-
jury occasioned by the wrongful act. The damages may be
assessed by taking the difference in the value of the land with
the injury and before the injury. But vindictive or exemplary
damages, sometimes called smart money, can not be allowed
unless malice or criminal intent is shown.’
1Stengly v. Barnard, 1 Rolle R. 88,12 Mass. 227; Panton v. Holland, 19
Johns 92; Farland v. Marshall, 19 Barb. 380; Humphries v. Bragden, 12
Q. B. 739; Foley v. Wyeth, 2 Allen 131; Solom v. Ventriesco, 4 Heal. &
Nor. 585; Lasala v. Holbrook, 4 Paige 169; Radcliff v. Mayer & Co., of
Brooklyn, 4 Conn. 195; Richardson v. Vermont Central Railroad, 5 Vt.
465.
© CHAPTER XI.
COLLISION.
DAMAGES IN CASES OF COLLISION, WHERE DEFENDANT IS SOLELY
TO BLAME. DAMAGES WHERE BOTH PARTIES ARE TO BLAME.
DAMAGES IN CASE OF A PARTIAL Loss. DAMAGES IN CASE OF
INJURY BY TWO VESSELS. THE cAUSES. THE ELEMENTS OF
DAMAGES. THE PLAINTIFF’S CHOICE OF COURTS. THE RULE
OF THE COMMON LAW AND ADMIRALTY THE SAME. DAMAGES
FOR THE CARGO. THEDEFENSE. THE AcT oF Gop.
199. Damage in Case of Misconduct of the Defendant. The
rule for the measure of damages in the case of collision be-
tween ships, steam and other boats on the seas, oceans, lakes
and rivers in case of an injury resulting in a total loss, caused
by the misconduct of the defendant or respondent alone, is the
market value of the vessel at the time of the injury or loss.
The Supreme Court of the United States in case of the ship At-
COLLISION. 167
las, in commenting on the question of damages, says: “Satis-
faction to the libellant for the injury sustained is the true rule
of damages.””
200. Damage Where Both Parties are in the Fault. The rule
laid down in the preceding section only applies in cases where
the injury is caused by the sole misconduct of the defendant or
respondent. But where both parties are to blame and the in-
jury complained of has been the result of the misconduct or
fault of both parties, a court of admiralty will add together the
damage done to both vessels and divide the aggregated amount
equally between the parties. This is virtually deducting the
less from the greater and dividing the remainer. And this
tule applies in all cases of mutual fault, whether the injury is
to one or both the vessels.
201. The Moiety Rule Applies Without Regard to Which was the
Most to Blame. On the trial of a case in a Court of Admiralty,
if the evidence discloses the fact that both vessels were in the
fault, the inquiry as to which was the most to blame will be
considered immaterial, as the damages must be divided be-
tween the parties according to the moiety rule established by
such courts.®
193 U. 8. R. 302; W. Roberts, 297; the Baltimore, 8 Wall 377; 1 Parson
on shipping, 542; the Granite State, Bl. & H. 347; the New Jersey, Olcott
444, 6 N. Y. 312; the Shannon, 1 W. Robert, 470; the Itinerant, 2 id. 243;
the Locklibo, 3 Rob. 318; the Morning Light, 2 Wall 560.
The actual damages sustained by the party at the time and place of
injury, and not probable profits at the port of destination, ought to be
the measure of damages. Smith v. Condry, 1 How. 28.
2 Williams v. Barrett, 13 Howard 101; the Atlas, 93 U. S. 302; the
Sapphire, 18 Wall 51.
Where both vessels are in fault, the sum representing the damages
are added together and the amount equally divided between the par-
ties, and that rule prevails in all cases where it is mutual fault. Vaux
-y. Sheffer, 8 Moore P. C. ©. 87. 7 a
Both vessels being in fault, the positive rule of the Court of Ad
168 LAW OF DAMAGES.
203. Damages in Case of Injury not Resulting in Total Loss.
Restitutio in Integrum is the leading maxim in cases resulting
in a partial loss, and where repairs are practical the rule fol-
lowed by the Admiralty Courts in such cases are that the
damages assessed against the respondent for injury caused by
his fault or misconduct alone, shall be sufficient to restore the
injured vessel to the condition in which she was at the time
the injury was inflicted. It may be laid down as a general
rule that in all cases of this character the measure of compen-
sation shall be equal to the amount of the injury.’
208. Jn Case of an Injury Occasioned by Two Vessels. Where
a collision occurs from the fault of both vessels and damages is
thereby done to an innocent party as the owner of a cargo of
either, or toa vessel in tow without fault, a decree should be
rendered not against both vessels zn solido for the entire damage,
interest and costs, but against each for the moiety thereof so
far as the value extends,> and it should provide that any bal-
ance of such moiety over and above such stipulated value of
either vessel, or which the plaintiff or libellant shall be una-
ble to collect or enforce, shall be paid by the other vessel to
miralty, says Lord Denmon, requires the damages done to both ships to
be added together andthe combined sum to be equally divided between
them as having been occasioned by the fault of both. Hay v. Lecher,
2 Shaws H. of L. cas. 400; the Washington, 5 jur. 1067; the Atlas, 93 U. S.
R. 302.
* The Baltimore, 8 Wall 377; Williamson v. Barrett, 13 Howard 110;
the Gazella, 2 W. Robinson 281; Sedgewick on dam (4 ed.) 541; Mc-
Lockland on shipping, 285.
5 Gamecock, 91 U.S. R. 605.
Allowance for freight is made in such cases recovering the gross
freight, less the charges, which would necessarily have been incurred in
earning the same, and which were saved to the owner by accident, to-
gether with interest on the same from the date of the probable termina-
tion of the voyage. The Baltimore, 8 Wall 377; the Canada, Lush. 586.
~
COLLISION. 169
the extent of the stipulated value beyond the moiety due from
her.®
/
204. The Causes. It is quite obvious to every thoughtful
man that disasters on the waters of this kind occur from dif-
ferent causes and under varying circumstances, but the rules
of the admiralty law are so framed as to meet the different cir-
cumstances which give rise to the accident. It may be laid
down, therefore, as a general rule that accidents of this charac-
ter occur under four possibilities :
1. It may happen without blame being imputable to either
party, as where the loss is occasioned by storm or any other vis
major. In that case the loss must be borne by the party on
whom it happens to fall, the rule being the party that is not
injured is not responsible to the injured party in any degree.
2. The misfortunes of the kind may and frequently do arise
where both parties are to blame, as where it appears that’
there has been a want of due diligefice or skill on both sides.
In such cases the loss must be apportioned between them as
being occasioned by both.
3. It sometimes happens by the misconduct of the suffering
party only, and then the rule is that the sufferer must bear his
own burthen.
4, It may happen from the fault of the ship which ran the
other down.’
205. The Elements of Damages. The elements of damages
in case of an injury not resulting in a total loss are:
692 U.S. R. 695. .
7 'The Atlas, 93 U. 8. R. 302; the Woodrop, 2 Dodson 85,
170 LAW OF DAMAGES.
1. The expense of the plaintiff, necessarily incurred in re-
taining his crew after the collision and in attempting to save
the cargo.’
2. The cost of repair.’
8. The rental value of the vessel while undergoing repair.’
4. Interest on the amount recovered.’
5. The injury to the cargo.‘
In case of a loss of a cargo by a collision, the plaintiff or
libellant can only recover its value where the ship or boat and
her cargo constitute one opposing force and a single ship or
boat the other. Where the vessel and cargo belong to the
same owner in aggregating the damages, the court will con-
sider the vessel and her cargo on one side and the single vessel
on the other, and award,a moiety of the loss to each. But
where the cargo belong to a stranger and is injured, he is en-
titled to full compensation for his whole loss, and if the injury
was caused by the misconduct of both vessels the court will
apply the moiety rule, but if it should happen that the owner
of the cargo is unable to collect the moiety from either of the
parties, he would have recourse on the other. And for the
purpose of preventing litigation and expense the Admiralty
Courts enter their decrees that each vessel pay a moiety of the
loss so far as the stipulated value of said vessel shall extend,
1 Hoffman v. Union Ferry Co., 68 N. Y. 385,
* Hoffman v. Union Ferry Co., 68 N. Y. 385.
5 Alabama v. The Gamecock, 92 U.S. R. 695.
‘Hoffman v. Union Ferry Co., supra; the Alabama y. the Game-
cock, 92 U. 8. R. 695; the Sapphire, 11 Wall 51; the Baltimore, 18 Wall-
377.
COLLISION. 171
and any balance of such moiety over and above such stipulated
value of either vessel, or which the libellant shall be unable to
collect or enforce, shall be paid by the other vessel or her stip-
ulators to the extent of the stipulated value beyond the moiety
due from said vessel or her stipulators to the extent of the stip-
ulated value thereof beyond the moiety due from said vessel.?
206. The Plaintif’s Right at Common Law. Where the
plaintiff has been injured and suffered loss he may bring his
action in a common law court against all the wrong-doers or
any one of them, and if he did not contribute to the disaster
he will be entitled toa judgment for the full amount of his
loss. If he sues the wrong-doers all jointly and has judgment,
‘he cannot afterwards sue them separately, or if he sues one
separately and has judgment he cannot afterwards sue them
all in a joint action, because the prior judgment against one
is, in contemplation of law, an election as to that one to pursue
his several remedies, but is no bar to the suit for the same
wrong against any one or more of the other wrong-doers.*
207. The Rule of the Common Law and of the Admiralty Law
are the Same in, Certain Cases. Contributory negligence on the
292 U.S. Rept. 695; the Washington and the Gregory, 9 Wall 516.
Experience shows that injured vessels sunk, especially when the
disaster happens in givers or harbors, may be raised at
moderate expense, and ‘that the cargo, if perishable, may be saved and
restored to the shipper or carried forward to the port of destination, and
the rule in such cases is to award such damages only as will compensate
the owner for the loss incurred, which is held to include expenses of
raising the vessel and putting her in repair, with a proper allowance for
the loss of freight, for damage to the cargo and for detention of the vessel
during the time necessary to make repairs and fit the vessel to resume
her voyage. The Baltimore, 8 Wall 377.
5 The ship Atlas, 93 U. 8. R. 302; Murray v. Lovejoy, 2 Cliff 196; 8. C.
3 Wall 19; Smith v. Hines, 2 Sumn. 348; Webster v. Railroad, 38 N. Y.
261.
172 LAW OF DAMAGES.
part of the libellant cannot defeat a recovery in collision cases
if it appears that the other party might have prevented the
disaster, and that he also did not practice due diligence and
was‘guilty of négligence, and failed to exercise proper skill
and care in the management of his vessel. It is true that
proof of contributory negligence would defeat the plaintiff’s
action at common law, but as has already been said in Court of
Admiralty it is different, and the loss in such cases is appor-
tioned between the offending vessels, but the rule of the com-
mon law ‘and of admiralty is the same where the suit is pro-
moted by an innocent party, except that the moiety rule may
be applied in the admiralty, if all the parties are before the
court and each of the wrong-doers is able to respond for his
share of the damages. The measure of damages in either court
being full compensation for the injury suffered by the collision.‘
208. Damages for Cargo. Where goods shipped as cargo
and their owner is innocent of all wrong, he may sue the
owner of one ship or both either at common law or go into the
Admiralty Courts at his election, and if he can prove that
each by their misconduct contributed to the injury he will be
as much entitled to full compensation in the Admiralty Court
as at common law.’
209. The Defense. The defendant or respondent may de-
feat the plaintiff or libellant’s claim for damages by showing
that he in no way contributed to the injury. A universal
rule, recognized everywhere, is that freedom from fault is a good
and perfect defense in all claims for damages arising from col-
lision of vessels.®
The Atlas, 93 U. 8. R. 302; Colgrove v. The Railroad, 20 N. Y. 493;
Collins v. Hill, 8 C. B. 125; Vandeplank v. Miller, 1 Moore & Mal. 169.
5 The Atlas, supra.
°The ship Atlas, 98 U. S. R. 302; the Shannon, 1 W. Rob. 470; the
Itinerant, 2 W. Rob, 243, 2 id, 318; the Morning Light, 2 Wall 560.
NUISANCE. 178
210. The Acts of God a Good Defense. Inevitable accident
is a good defense in all controversies of this character, where
both vessels are free from blame, but it is utterly unavailing
if either or both were in the fault. The rule is that where the
collision occurs exclusively from a natural cause without any
fault of either of the parties, there can be no recovery, and the
loss must rest where it happens to fall.’
7 The Atlas, 93 U. S. R. 302.
CHAPTER XII.
NEGLIGENCE.
NEGLIGENCE DEFINED, IN oRDER FOR PLAINTIFF TO RECOVER
HE MUST SHOW A CASE OF UNMIXED NEGLIGENCE, ExXcEp-
TION TO THE GENERAL RULE, MALICE, PROXIMATE AND
REMOTE. THEILLINOIS RULE. GREAT DIFFICULTY IN LAY-
ING DOWN A GENERAL RULE. THE RIGHT TO USE PROPERTY
THE PLAINTIFF MAY RECOVER IF THE INJURY OCCURRED
FROM THE DEFENDANT’S INEXCUSABLE NEGLECT. APPLICA-
TION OF THE RULE IN CASES OF GROSS NEGLIGENCE. APPLI-
CATION OF THE RULE IN CASE OF CONTRIBUTORY NEGLIGENCE,
INJURY TO A CHILD. CoNTRIBUTORY NEGLIGENCE OF PAR-
ENTS, &C. REMOTE CONSEQUENCES. THE RULE AS TO THE
POINT WHERE PECUNIARY LIABILITY WILL CEASE NOT DEFI-
NITELY SETTLED. How to ASCERTAIN WHETHER THE DE-
FENDANT IS LIABLE. THE CONFLICTING VIEWS. DAMAGES
211. Negligence Defined. The word negligence in its
broadest sense includes almost every breach of duty not clearly
intentional. Thus we say a man has neglected his business
or neglected to perform his contract, but it has a legal defini-
tion that is generally understood to be “omitting to do some-
NEGLIGENCE. - 175
thing that a reasonable man would do, or doing something
that a reasonable man would not do; in either case causing an
unintentional injury to a third party.”
212. In Order for the Plaintiff to Recover he Must Show Un-
mixed Negligence. As a general rule where negligence is the
issue it must be a case of unmixed negligence to authorize a
recovery, and if both parties by their negligence immediately
contributed to the injury neither can recover.? But it is only
the contributory fault of the injured party or of some one
whose fault is imputable to him, that will exculpate the de-
fendant. He cannot defeat the plaintiff’s claim for damages
by showing that the conduct of a mere stranger contributed to
the injury.’
1 How. v. Young, 16 Ind. 312; 1 Hill on Torts, 124; Shearman & Red-
field on Neg., Sect. 1; Touawanda R. Co. v. Munger, 5 Denio 255-267;
Gardner v. Heart, 3 Denio 232; Amick v. O’Hara, 6 Black 258; Tally v.
Ayres, 3 Sneed 677.
Negligence is the failure to do what a reasonable and prudent person
would ordinarily have done under the circumstances of the situation, or
doing what such a person under the existing circumstances would not
have done. The essence of the fault may be in omission or commission.
Railroad Co. v. Jones, 95 U. S. 439.
2 Butterfield v. Foster, 11 East 60; Evansville & C. R. R..Co v. Heath,
17 Ind. 102; Lofton v. Vogles, 17 Ind. 106; Evansville R. R. Co. y. Lou-
dermilk, 15 Ind. 120; the Toledo & Wab. R. R. Co. v. Thomas, 18 Ind.
215; Brooks v. the Buffalo, &c , R. R. Co., 25 Barb. 600; Smith v. Smith,
2 Pick. 621; Sudam v. the Street R. R. Co.; 41 Barb. 375; Runyon v. the
Central R. R., 1 Ducher 558; Dascomb vy. Erie R. R., 27 Barb 221;
Mackey v N. Y. Cen. R. R. Co., 27 Barb. 528; Button, Adm., v. Hud-
son Riv. R. Co., 18 N. Y. 248; Brown v. Maxwell, 6 Hill 592; the Cleve-
land R. R. Co. v. Ferry, 8 Ohio 570; Clark v. Kernan, 4 E. D Smith 21;
Owen v. the Hudson R. RB. Co, 4 Boston 37; Munch y. the Concord, 9
Fost. 9; Moore v. the Central R. R. Co., 4 Zabb 268-828; the Toledo R. R.
€o. v. Goddard, 25 Ind. 185; the Michigan Southern and North Ind. R.
R. Co. v. Lantze, 29 Ind. 528; E. &C. R. R. Co. v. Dexter, 24 Ind. 411; Jeffer-
sonville R. R. Co. v. Swift, 26 Ind. 459; Toledo, Wabash & Western R R.
Co. v. Brenin, 26 Ind. 448; the Lafayette R. R. Co. v. Bruer, 28 Ind. 287;
L, P. & C. R. R. Co. v. Rubey, 23 Ind. 133; the Chicago & Mississippi v.
.
176 LAW OF DAMAGES.
And the contributary negligence by the plaintiff must be
proximate and not remote, and it must be a negligence
occurring at the time the accident happened. If the plaintiff
had by his previous negligence placed himself in a helpless
condition and this fact was known to the defendant, the plain-
tiff can recover if at the time when the injury occurred it
might have been avoided by the exercise of reasonable care by
the defendant.’
Packen, 16 Ill. 198; G. C. U. RB. R. Co. v. Dill, 22 Ill. 264; Ill. Central R.
R. Co. v Phelps, 29 Ill. 447; Pennsylvania v. Hedson, 43 Pa. st. 449;
Beswig v. N: Y. Cen. R. R. Co., 40 N. Y. 9; Haven vy. the Erie R. W. Co.,
41 N. Y. 296; Stedly v. London & N. W. R. W. Co., LR. 1 Ex. 13; But-
terfield v. the Western R. R. Co., 10 Allen 532; Bellefontaine R. R. Co.
v. Hunt, adm., 33 Ind. 355; 1 Hill on Torts, 125-126; Spooner v. Brook-
land R R. Co., 54 N. Y. 230; 13 Am. R. 570; Sherarman & Redfield on
Neg., p. 29 and 30.
The plaintiff lent his gun to four boys, the defendants The gun was
loaded. The boys returned the gun loaded with a dangerous charge and
told him they had not discharged it, for the mischievous purpose of
having the plaintiff kicked when he might shoot it off. Plaintiff sus-
pected the boys of falsehood; tried to see them, but did not; examined
the gun for himself; found from six to eight inches of load in it; then
discharged it voluntarily, holding it around the corner of the house to
shield himself, and was wounded. Held, that the conduct of the boys
was not the proximate cause of the injury. Smith v. Thomas, 23
Ind. 69; Indianapolis co. v. Wright, 22 Ind. 376.
5 Austin v. Steamboat Co., 43 N. Y. 75; 3 Am. R. 663; 28 N. Y. 256;
Davis v. Mann, 10 M. & W. 545; Haley v. Earl, 830 N. Y. 208; 40 Vt. 487;
Cummings v. Spruce, 4 Harr 315; Stout v. Foster, 1 How. U.S. 89; C.,C.
&C.R R. Co. v. Crawford, 24 Ohio st. 631; Timmons vy. Central R. R.
Co., 6 Ohio st. 105; Wright v. Gaff et al., 6 Ind. 416; E.& C. R. R. Co. v.
Hiatt, 17 Ind. 102.
Where the plaintiff rode upon the locomotive of the defendant with
notice that it was contrary to the defendant’s orders to the engineer, it
was held that the plaintiff could not recover for an injury received
.through the defendant’s negligence while on the engine. Robinson v.
the N. Y. & Erie R. R. Co, 22 Barb. 91; Button v. Hudson Riv. R R.,
24.N. Y. 430; Johnson v Hudson River; Delafield v. Union Ferry Co.,
10 Bosw. 216; Morris v. Phelps, 2 Hilt 38; Menges v. Harlam R. Co., 1
Hilt 425; Clark vy. Kirwan, 4 E. D. Smith 21. Sometimes the language
used is that the plaintiff cannot recover if his own negligence concur.
Hance v, Cayuga R. Co , 26 N. Y. 428; Tuff v, Warman, 5 C. B. 573; Davis
NEGLIGENCE. 177
213. Exception to the General Rule. It is now pretty gener-
ally settled that where the negligence of the defendant is so
gross as to imply a disregard of consequences, or a willingness
to inflict the injury, the plaintiff may recover, though he be a
trespasser or did not use ordinary care to avoid the injury.‘
v. Mann, 10 Mees. & W. 546; Scott v. Dublin & R. Co., 11 Irish C. L. 377;
Wright v. Brown, 4 Ind. 95; Lafayette-& C. R. Co., 26 Ind. 76; Ker-
whacker v. Cleveland & R, Co., 3 Ohio st. 172; Louisville R. Co. v. Col-
lins, 2 Duvall 114; Morrissy v. Wigging Ferry Co. 43 Mo. 380; Foster v.
Holly, 38 Ala. 76; Chicago R. Co. y. Still, 19 Ill. 499; Button v. Hudson
R. Co., 18 N.Y. 248-258.
4 The Latayette and Indianapolis R. W. Co. v. Adams, 26 Ind. 76; In-
dianapolis & Pittsburg R C v. Petty, 30 Ind. 261; E. & C. R R. Co. v.
Loudermilk, adm., 15 Ind. 120; Ohio and C. & C. R. Co. v. Gullett, id. 87;
Stuke v. Milwaukee, 9 Wis. 202; Wherely v. Whiteman, 1 Head 610;
Macon & Co. v. Davis, 27 George 113; 1 Hillard on Torts, 125-126.
There is a manifest want of uniformity in the authorities in their at-
tempt to define the precise circumstances under which the plaintiff may,
recover for an injury when it is shown that he, by his negligence, con-
tributed to the injury for which he sues, and it is to be regretted that
this want of uniformity prevades some of the cases heretofore decided
by this court, but we think many of the apparent differences which
have arisen on this subject result more from inapt use of words and
phrases than from any difference in the ideas intended to be expressed.
There has been of late a very strong tendency of judicial opinion ad-
verse to the distinction between gross negligence and ordinary negli-
gence in the sense in which those terms are used in the class of cases to
which we have above referred, and with that tendency the doctrine has
been gaining ground in this and at least in some of the other States that
something more than mere negligence, however gross, must be shown to
enable a party to recover for an injury when he has been guilty of con-
tributory negligence; that in such cases something more aggressive than
mere negligence must be alleged and proved. Strictly speaking, negli-
gence is non-feasance, not a malfeasance. It is an act of omission
rather than commission. The Pennsylvania Co. v. Sinclare, 62 Ind. 301;
Shearman & Redfield on Neg., Sect. 2; Wharton on Neg., Sect. 22; O. R.
W Co. v. Shelby, 47 Ind. 471: R. R. Co v. Lockwood, 17 Wall (U. 8.)
357. The wrong-doer is always liable for the result of his willful,
malicious act, although the act of the plaintiff contributed to the injury.
Ml. Cen. R. Co. v. Hutchison, 47 IL. 408.
178 LAW OF DAMAGES.
So where the negligence of the defendant is proximate
and that of the plaintiff remote he may recover.®
214, The Illinois Rule. The Supreme Court of the State
of Illinois has held, in several well considered cases, that the
plaintiff may recover if he can show that notwithstanding the
fact that he may have been guilty of some contributory negli-
gence, still, if it was slight as compared to the defendant’s
negligence, he should have judgment, but it must appear that
the defendant’s negligence clearly and largely exceeded that
of the plaintiff’ This rule is in direct conftict with the most
recent authority. Indeed, the tendency of the modern de-
cisions are to the effect that it is only when the injury sued
for is alleged either in terms or in substance to have been
willfully or purposely committed that contributory negligence
ceases to be a defense.’
215. The Great Difficulty in the Way of Framing a General
Rule. Courts have found it quite difficult to frame a definite
and satisfactory rule on the subject of mutual negligence of
®° Mississippi R. R. Co. v. Mason, 51 Min. 234; Johnson v. C. R. R. 27
La. 53; Manly v. Williamington, 74 N. C. 655; Cleander R. R. Co v.
Elliott, 28 Ohio st. 340.
Where a parent suffers a child two years and nine montbs old to
wonder unattended eight hundred and seventy-five feet from its home,
near a railroad, and there to go upon the railroad tract and was injured,
- it was held that there was such contributory negligence that the parent
could not recover for the death of the child. O. & M.R.R Co. v.
Dickson, 59 Ind 89; Indianapolis R. R. Co vy. Bowen, 40 Ind. 545, 49:
Ind. 154; T., W. & W. R. R. Co. v. Shuckman, adm., 50 Ind. 42; I. & St
L. R. R. Co. v. Stout, 53 Ind. 148.
"Chicago R. R Co. v. Clark, 70 Ill. 276; 1 R. R. Co. v. Craiger, 71
Ill. 177; T. R. BR. Co. v. McGinnis, 72 Ill. 141; Ill. R. R. Co. v. Hall, 72
Ill. 222; R. R. R. R. Co, v. Hillmen, 72 Ill, 235, 347, 386, 404, 504, 394;
Litchfield Coal Co. v. Taylor, 81 Ill. 595, at 379, 38 Ill. 485.
° Penn. Co. v. Sinclair, 62 Ind. 301.
NEGLIGENCE. 179
the parties. And there is at this time a manifested want of
harmony and uniformity among the authorities in their at-
tempt to define the precise circumstances under which the
plaintiff may recover for an injury when it is shown that he,
by his own negligence, has directly contributed to the injury
for which he sues. The tendency of the modern judicial
opinions is adverse to the distinction between gross and
ordinary negligence. “These expressions are indicative rather
f the degree of care and diligence, which is due from a party
and which he fails to perform, than of the amount of inatten-
tion, carelessness or stupidity which he exhibits. If very lit-
tle care is due from him and he fails to bestow that little, it is
called gross negligence. If very great care is due and he fails
to come up to the mark required, it is called slight negligence.
And if ordinary care is due, such as a prudent man would ex-
ercise in his own affairs, failure to bestow that am ount of care
is called ordinary negligence. In each case the negligence
whatever epithet we give it, is a failure to bestow the care and
skill which the situation demands, and hence it is more strict-
ly accurate to call it simple negligence.” It certainly would
be more accurate to draw the line between acts of omission and
commission; for, strictly speaking, negligence is non-feasanée,
not malfeasance. It isan act of omission rather than commis-
sion. Wherea bad intention enters into an act, whether that in-
tention be actual or constructive only, the wrongful act ceases
tobe merely a negligent injury, and becomes one of violence or
aggression. In order then for the plaintiff to recover, where
his own negligence has directly contributed to the injury, he
must allege and prove either in terms or substance that the
defendant committed the wrongful act willfully or purposely.’
7 Railroad Co. v. Lockwood, 17 Wall 357.
1 Pa. Co. v. Sinclair, adm., 62 Ind. 301; Wharton’s Neg., 8. 22; the Ohio
Co. R. W. v. Shelby, 47 Ind. 471; Railroad Co. v. Lockwood, 17 Wall 357;
Cin. & Mart. R. R. Co. v, Eaton, 53 Ind. 307.
Negligence, in correct legal phraseology, is more nearly synonymous
180 LAW OF DAMAGES.
216, The Right to Use Property Does Not Authorize One to do
Wrong. The law gives the owner of property the free and ex-
. elusive use of it, but it requires him to use it in such a way as
not to do any unnecessary or avoidable injury to another, and
the fact that one party is in the wrong does not of itself dis-
charge another from the observance of due and proper care to-
wards him, or of the duty of exercising his own rights or using
his own property as not to injure him unnecessarily. It may,
therefore, be laid down asa rule that while a party on the one
hand shall not recover damages for an injury which he has
brought upon himself, neither shall he on the other hand be
permitted to shield himself from an injury which he has done
because the party injured was in wrong, unless such wrong,
contributed to produce the injury, and even then it would
seem that the party setting up such defense is bound to use
ordinary caution to be in the right.’
with carelessless than with any other word. It signifies primarily the
want of care, caution, attention, diligence, skill or discretion in the per-
formance ofan act by one having no positive intention to injure the per-
son complaining thereof. Where such intention exists the act ceases to
be merely negligence, and becomes one of violence or fraud. Shearman
v. Redfield on Neg., Sect. 2.
1 Kerwhacker v. the 0, C. & C. N. R. R. Co., 3 Ohio State 172; Wright
* y, Brown, 4 Ind. 95; Brown v. H. & St. Joe R. R. Co., 50 Mo. 461; Trans-
portation Co. v. Vanderbilt, 16 Conn. 421; Bright v. Gardner, 19 Conn.
507; Vere v. Lord Cawdor, 1 East 568; Mayor of Colchester v. Brooks, 53
Eng. com. law 376.
Where a person is walking on a railroad track and is run over and
killed by an engine belonging to the railroad company, the company is
responsible in damages for such killing, though the deceased was guilty
of a want of ordinary care and prudence in so walking on the track,
provided it appears that the accident would not have occurred if the
agent of the railroad company had used, in running the engine which
occasioned the killing, ordinary prudence in giving reasonable and usual
signals of its approach and in keeping a reasonable lookout. Baltimore.
& Ohio R. R. Co. v, State, 36 Md. 366; see Shields v. Blackburn, 1 Hen.
Black 158; Moore v. Morgue Co., 480 Bulls E. P. 73; Broom’s Legal Max.
248, Puffendorf’s Law of Nature, B. III. ch. I.; Rutherford Inst. of
Natural Law, p. 201; Bird vy. Holbrook, 15 Eng. com. law rep, 559;
NEGLIGENCE. 181
217. The Plaintiff may Recover if the Injury Occurred from In-
excusable Neglect. If the plaintiff was in the fault, yet he may
recover if the injury for which he sues was occasioned by the
inexcusable neglect of the defendant.” .
218. Instances of the Application of the Rule in Case of Gross
Negligence: Where the track of a railroad passed through a cut
eight rods long and a horse of the owner of the land was near
the entrance of the cut, and the whistle of the approaching en-
gine was sounded, and the horse ran upon the track and into
thecut, from whence it could not escape upon the side, and the
engine was run on and the whistle sounded, thereby continu-
ing to frighten the horse, until it jumped into the trestle
work and was killed. It appered dn the trial that the engine
could have been stopped after the horse got into the cut, and
before he jumped into the trestle work. The court held that |
Raisin v. Mitchell, Nal. 38 Eng. com. law rep. 252; Dean v. Clayton, 2
Eng. com. law rep. 183; Vaughan v. Melone, 3 Bing. N. C. 486; Dixon v.
Bell, 5 M.S. 198; Sedgewick on dam. 471; Cook v. Champlain Trans.
Co., 1 Denio Rep. 89. In which it was ‘held that where a person in
lawful use of his own property exposes it to the danger of accidental in-
jury from the lawful acts of others, he does not thereby loose his remedy
for an injury caused by the culpable negligence of such other person, so
that the owner of land on the shore of a stream‘or lake or adjoining the
tract of a railroad, may lawfully build on his land, though the situation
be one of exposure and hazard and be nevertheless entitled to protec-
tion against the negligent acts of persons lawfully passing the same
with vessels or carriages propelled by steam engines by which such
building may be set on fire, on the ground that the owner undertook
the risk and hazard of injury by mere accident, but not the risk of in-
jury by negligence. See Quinby v. the Vt. Cen. R. R, Co, 23 Vt. Rep.
388, 14 Paige Rep. 553; Amick v. O’Hara, 6 Black 258; Weaver v. Ward,
Hobart 1384; Haycraft v. Crease, 2 East 92; L. Kenyon, Indianapolis &
Cin. R. R, Com. v. Caldwell, 9 Ind. 397.
2 Ind. & Cin. R. R. Co. v. Caldwell, 9 Ind. 397; Pa. Co. v. Sinclair, 62
Ind. 301; I., B. & W. R. R. Co. v. McBrown, 46 Ind. 229; B. & O. R. R.
Co v. State, 36 Md. 366; the C., C. & C.R. R. Co. v. Crawford, 24 Ohio
st. 631; Timons v. Central Ohio R. R. Co. 6 Ohio st. 105.
182 LAW OF DAMAGES.
the horse was killed by the willful misconduct of the defend-
ant.
219. A lady was walking on the street of a populous
town, when the locomotive of a railroad company was also pass-
ing thesame place. She was, while on the track, run over
and injured. She brought suit for damages. The train was
running at the rate of ten or twelve miles per hour. The
court held that the rate of speed was so great as to show that
those managing the train had no care whatever as to who or
how many might be killed or injured. The employees of the
railroad company did not see the plaintiff until a moment
before she was struck. The court held that the plaintiff was
wilfully or purposely injured.*
220. And where a person was walking ona railroad track
and was killed by an engine belonging to the defendant, the
court held that the company was responsible in damages for
such killing, though the deceased was guilty of a want of care
-and prudence, provided the accident would not have happened
if the agent of the defendant had used ordinary prudence and.
care in running the train which caused the death, and ordinary
care and prudence in giving reasonable and the usual signals
of its approach, and in keeping a reasonable lookout.®
21, B. & W.R. R. Co. v. Merown, 46 Ind., 220.
*L. IR. R. Co vy. Adams, 26 Ind., 76. If the wrong on the part of the
defendant is so wanton and gross as to.imply a willingness to inflict the
the injury the plaintiff may recover, notwithstanding his own ordinary
negligence. Hawkins v. Cooper, 34 Eng. Com. Law, 842. Ind. & Cin.
R. R. Co. v. MeCluer, 26 Ind. 370. L. & I. R, R. Co. v. Huffman, 27 Ind.
287.
* Baltimore, etc. R. R Co. v Stae, 36 Md., 366. See also Brown v. H
& St. Joseph R. R. Co, 50 Mo. 461; Thompson v. North Mo. R. R. Co., 51
Mo., 190; Huel Senkenkamp v. Citizens’ R. R. Co , 37 Mu., 537, Lynch
v. Nurdin, Ala. & El, (N, 8.) 29; Burdge v. Gardner, 19 Conn., 507.
NEGLIGENCE. 183
221. Application of the Rule in Case of Contributory Negligence.
It is settled that ordinary prudence’ requires a person in the
full enjoyment of his faculties and senses to use them before
attempting to cross a known railroad track for the purpose of
avoiding danger from a passing train, and a failure to do so
without a reasonable excuse therefor is negligence, and will de-
feat an action for injury to which such negligence contributed.*
222. So if a footman enters upon a street crossing in a city
where the moving vehicles are numerous, and a collision with
them is likely to produce serious injury, without first looking
in both directions along the street to ascertain where any are
approaching, and if so their rate of speed and how far a dis-
tance they are from the crossing, he is chargeable with con-
tributory negligence that will defeat an action for an injury
oceasioned by such negligence. These decisions rest on the
ground that vehicles and footmen each have the right of pass-
ing in common, and in its use are bound to exercise reasonable
care for their own safety and to avoid doing injury to others
who may be in use of the right of way with them.
223. Where Injury Occurs to a Child. The authorities are
very much in conflict as to what degree of care should be re-
The C., C.C. R Co.,v. Crawford, 24 Ohio st , 631; 15 Am. Rep. 633
Toledo & Wabash R. R. Co. v. Goddard, 25 Ind., 185; Stines v. O. & S.
R. R. Co., 18 N. Y. 422, 29 Id. 315; 25 Barb. 600, 13 Id. 9; E& C. R. RB.
Co. v. Hiatt; 17 Ind., 102; Same v. Loudermilk, 15 Ind., 120, Steele v.
Burkhardt, 104 Mass., 59 Kearus v. Snowden, 104 Mass., 63: Nicholson
vy. the Erie R. R. Co., 41 N. Y. 542; Baxter v. Troy & Roston Co., 41 N
502; Harty v. Central Co., 42 N..Y., 472; Barker v. Savage, 45 N. Y., 191.
5 Baker v. Savage, 45 N. Y. 191; Stevens v. Oswego R. Co., 18 N. Y.
423; Ernest v- Hudson Riv R.R. Co 39 N. Y. 68; Wilcox v. Water-
town R. R. Co., 29N. ¥. 358-368; Griffin v. N. ¥. Cen. R R. Co., 40 N.
Y. 51; Nicholson v. Erie R. R. Co., 41 N. Y. 542; Baxter v. Troy & Boston
Co., id. 505; Harty v. Central R, R, 42 N. Y. 472; BONO v. Com.
Bench, (N. 8.) 571 S. C. 98, com. law 571.
184 LAW OF DAMAGES.
quired of a child of tender years, and whether the negligence
of those having the care:and custody of a child shall be im-
puted,to it. The caution and care required varies with the
capacity and maturity of the child, and this is to be deter-
mined by the jury from all the circumstances of the case.° It
looks like a bard rule that would hold a child to the same
legal rules in regard to care, danger and diligence in avoiding
the consequences of other’s negligent or wrongful acts that is
required of a person of full age and in possession of all his
physical and mental powers, but the law presumes that
parents, in accordance with the instinct of our natures, will
watch and guard with an unabating care the person of their
thoughtless and helpless offspring. This duty is enjoined
upon them by the law that is written in our mental constitu-
tions and clearly demonstrated: by our sympathetic. natures.
If they neglect this duty and their child is injured by the neg-
ligence of another, there can be no recovery.
For the reason that the parent is the natural guardian of
his child, who has the custody of its person and is responsible
for its safety, it is his duty to watch over and guard his child
§ Railroad Co., v. Gladman, 15 Wall 401.
The following instruction was held correct: The fault or negligence
of the deceased, which will preclude a recovery by the plaintiff if there
was mutual negligence, is not the least degree of fault or negligence, but
it must be such a degree as amounted to a want of ordinary care on the
part of the deceased at the time of the injury By ordinary care is
meant that degree of care which may be reasonably expected of a per-
son in the deceased’s situation. Although the deceased may have been
guilty of misconduct or negligence which contributed remotely to the
injury, yet if the misconduct, negligence, unskillfulness or criminal in-
tent of the defendant, its agent or servant was the immediate cause of
‘the injury, with the exercise and care the defendant might have pre-
vented the injury, then it isliable Leddy v. St. Louis Co., 40 Mo. 511;
see also Keefe v. the Chicago R. R. Co; 827id. 468; Sweeny v. Old
Colony, &c., Co., 11 Allen 369; Sells v. Brown, 9 C. & P. 601; Rigley v.
Huett, 5 Exch, 239.
NEGLIGENCE. 185
from danger and to provide for its welfare, and it is the duty
of the child to submit to his government and control. It is
entitled to his superintendence and protection, and is conse-
quently subject to the disadvantages resulting from the exer-
cise of that parental authority, which is both his right and
duty to exert. Any want of ordinary care, therefore, on the
part of the parent is attributed to the child in the same degree
as if it was acting wholly for itself.’
But it should be remembered that the only negligence of
those who have the control of a child that can be imputed to
it, is such as related to the exercise of their authority in con-
trolling the conduct and actions of the child. We think the.
true rule is that a child is chargeable with any negligence of
his guardian in putting or keeping the child in a position of
danger, or in permitting it to be in such position, but not for
any negligence of his guardian in an individual capacity.
Suppose, for illustration, that a child is riding on a boat pro-
pelled by steam with his guardian, and while the boat is in
motion the guardian, by some means, causes the boiler to the
engine ‘to explode, and the child is injured, the act of the
guardian could not be imputed to the child; or, suppose that a
father permits the gas pipe of his house to leak, his negligence
in this respect could not be chargeable to the child so as to bar
1 Pittsburg, Fort Wayne and Chicago R. W. Co. v. Vining, adm., 27
Ind. 513; Hughes v. Mayfie, 2 Hul. and Colt. 744; Morgan v. Atherton,
Law Rept Ex, vol. 1 page 239; Hatfield v. Roper et al., 21 Wend. 615;.
Holly v. Boston Gaslight Co. 8 Gray 123; Lynch v. Nurdyne, 12 B. 29;
Wait v. N. E. RB. Co., 96 E. Com L. 719; Singleton v. the Eastern R. R.
Co., 97 Eng: Com. L. 287; Campbell on Neg, Sect. 81; Lafayette R. R.
Co. v. Huffman, 28 Ind. 287; the Jeffersonville R R. Co. v. Brown, 40
ind. 545; Hathaway v. Toledo, &c., R. R. Co., 46 Ind. 25; Magam v.
Brooklyn R. Co., 36 Barb 230, 38 N. Y. 455; Flynn v. Hatton, 43 How.
Pract. 333; Leham v. Brooklyn, 29 Barb. 234; Kreig v Wells, 1E. D.
Smith 74; Callahan v. Bean, 9 Allen 404; Wright v. Malden, &c., R. R.
Co., 4 Allen 283; Chicago v. Starr, 42 Ill. 174.
186 LAW: OF DAMAGES.
an action by the latter for an injury caused by an explosion of
the gas through the defendant’s negligence. But it would be
different if the circumstances of the case made it the duty of
the father, as father, to remove his child from the house. His
failure to do so would be chargeable to the child precisely as if
he had been of full age and had neglected to remove.’
But if the parent or guardian has taken reasonable care
of the child and, notwithstanding the use of such care the child
escapes into a dangerous place and is injured, there is no negli-
gence on the part of the parent or guardian that can be im-
puted to the child.®
224. The Conflict of Authoritzes. As has already been said
the authorities are very much in conflict upon the question of
‘the amount of care that the law requires children to exercise
in avoiding danger. But as law and reason generally har-
monize, it may be laid down as a general rule that the caution
and care required varies with the capacity and maturity of the
child and the surrounding circumstances, and this is to be de-
termined by the court or jury trying the cause from all the
? The Pittsburg, Fort Wayne & Chicago R. R. Co. v. Vining, adm., 27
Ind. 513; Wright v. the Malden & Melrose R. R. Co. 4 Allen 283; Shear-
man & Redfield on Neg., S. 48 P 61; Lannen v. Albany Gas Co., 46
Barb. 264, 44 N. Y. 459; Lynch v. Smith, 104 Mass. 52; Ihl v. 42 D. St.
Co., 47 N. Y. 323; Hatfield v. Roper et al., 21 Wend. 615; Magon v. At-
terton Law Exch., vol. I 239; Holly v. the Boston Gas Light Co., 8 Gray
123; Campbell on Neg., 81.
8 Shearman & Redfield on Neg., Sect. 48, P. 61; Lannen v. Albany, 46
Barb. 264; affirmed 44 N. Y. 459; Honingsberger v. Second Avenue, &c.,
R. Co., 33 How. Pract. 193; reversing S C.1 Daly 89; Burke v Broadway
R. R. Co., 49 Barb. 529; 34 How. (N. Y.) 289; Horr v. Parks, 40 Cal. 188.
Unless there is unusual exposure to danger there is no negligence
whatever in allowing a child between ten and twelve years of ordinary
activity and intellect to be on the street. Horr v. Parks, 40 Cal. 188.
»
NEGLIGENCE. 187
facts and circumstances of the case.1 Reason would say as a
rule that less caution and prudence would be required of a
child five years old than one ten years old, and of one ten years
old than of one fifteen. The law recognizes the fact that chil-
dren, and especially those of tender years, are incapable of ex-
ercising that degree of care that is ordinarily expected of per-
sons of mature years, from the fact that they are incapable
of reasoning from cause to effect and of apprehending the dan-
ger that surrounds them. Thus, where a child was permitted
by his parents to cross the street, and while crossing he was
injured by the negligence of a traveler, the court held that the
child could recover for the injury if he was using that degree
of care of which he was capable to avoid the injury, though it
was a less degree than an adult would have used under the
circumstances.”
225. The General Rule in Reference to Children. The weight
of authority in this country is almost unanimously in favor of
holding an infant, so far as he is personally concerned, only to
such degree of care as is usual among children of his age.
Therefore, what would be considered negligence on the part of
an adult might not, under exactly the same circumstances, be
' Railroad Co v. Gladman, 15 Wall (U. 8.).401; Stout v. Sioux City,
&ce, R. R. Co., 2 Dill C. C. 294; Field on the law of dam., Sect. 192.
* Lynch v. Smith, 104 Mass. 52; Field on the law of damages, S. 192:
Shearman & Redfield on Neg.; see Ihl v. 42 R. Co., 47 N. Y. 323; Mc-
Mahon v. New York, 33 N. Y. 64.
Where the defendant exposed in a public place for sale, unfenced and
without superintendence, a machine which. might be set in motion by
any passer-by and was dangerous when in motion, the plaintiff, a boy
four years old, by the direction of his brother, seven years old, placed his
finger within the machine while another boy was turning the handle
which moved it, and his finger was crushed, the court held that he
could not recover for the injury. Magon v. Atterton Law Rep. Ex., vol.
1 p. 239; see Hughes v. Macfie, 2 Hurls & Colt 744; Holly v. Boston Gas
Light Co., 8 Gray 123. .
188 LAW OF DAMAGES.
considered negligence on the part of achild. The law judges
of the negligence by the capacity or ability of the party to
comprehend the danger that surrounds him.®
226. State in Which the Contributory Negligerice of Parents and
Guardians are Held to be No Defense. In Vermont, Connecticut,
Pennsylvania, Ohio, and perhaps in Missouri, the whole doc-
trine that the negligence of the parent or guardian is to be
imputed to the child is repudiated, and it is held that such
negligence is not to be considered in an action brought by a
child.’
227. The Distinction Where the Action is Brought by the Parents.
The decision of almost all the courts of this country draw a
distinction between action by or on behalf of parents or other
persons and action by the injured child. They uniformly
hold that in an action brought by the parents or representa-
® Railroad Com. v. Gladman, 15 Wall (U. S.) 401; Ihl v. 42d St. R. Co.,
47 N. Y.317; Mangam v. Brooklyn R. Co., 38 N. Y. 455; O’Mara v. Hud-
son R. Co., 38 N. Y. 445; Rauch v. Lloyd, 31 Pa. st. 358; Pa. Co. v. Kelly,
id. 572; Smith v. O’Connor, 48 Pa, st. 218; North Pa. R. Co. v. Mahony,
57 Pa. st: 187; Robinson v. Cone, 22 Vt. 213; Munn v. Reed, 4 Allen 431;
Lynch v. Smith, 104 Mass. 52; Berger v. Gardner, 19 Conn. 507, Brown
v. Southberry, 37 Conn. 199; Lynch v. Nurdine, 12 B. 29; Baltimore R.
Co. v State, 30 Md. 47; Schmidt v. Milwaukee, &c., 23 Wis. 186; Kerr v.
Forgue, 54 Ill. 482; O’Flarherty v. Union R. Co, 4 Mo. 70; P. R Co. v.
Spearen, 47 Pa. st. 30; Chicago R. R. Co. v. Denny, 26 Ill. 255; Rockford,
&c., R. R. v. Delany, 82 Ill. 198; McMillan v. Burlington, &c., R Co., 46
Iowa 231.
Where the question of constructive negligence is raised as to acts of a
young and inexperienced person employed in a dangerous vocation, his
acts are to be judged with reference to his youth and experience. St.
Louis R. Co. v Valerius, 56 Ind 511.
* Robinson v. Cone, 22 Vt. 213; Daly v. Warrick Co., 26 Conn. 591;
North Pa. R Co. v. Mahony, 57 Pa. st. 187; Smith v. O'Connor, 48 id,
218; Bellefontaine R. R. Co. v. Snyder, 18 Ohio st. 239; Mo. opinion of
Wagner, J., in Isebel v. the Hannibal, &c., R. R., May term, 1815, Cent.
L. J., vol. 2, p. 590,
NEGLIGENCE. 189
tive of the deceased that there can be no recovery if the evi-
dence shows that the injury was caused by the contributory
negligence of those to whom the law gives the damages. This
rule is based upon the old maxim that a man shall not take
advantage of his own wrong and in pari delicto potior est conditio
defendentis, And it may be laid down as a general rule that
when a parent or master or representative sues for the loss of
service, caused by the‘injury to the child, there can be no re-
covery, if the real plaintiff or the party who is entitled to the
damages by his negligence directly contributed to the injury.‘
\
228. The Degree of Care Required of a Defendant When Chil-
dren are Likely to be Injured. Where the question is one of sim-
ple negligence we think that the weight of authority makes
no distinction between the case of a child unnecessarily ex-
posed and that of a person of mature years, but where the
question becomes one of gross negligence the rule is not the
same. Thus, if the engineer of a locomotive discovers a child
on the railroad track, the law would require him to use greater
eftort to stop the train than if had discovered a grown person
in the same situation. In the latter case he could reasonably
presume that the adult would use a reasonable effort to save
himself from injury, but in the former he could entertain no
such presumption.®
229. Drunkenness. The fact that the plaintiff, at the time
the accident happened was in a state of intoxication will not
excuse him from using that degree of care that the law re-
4 Glassey v. Hestonville & R. Co., 57 Pa. st. 172; Birmingham v. Dorer,
30 Brewster 69; Field on the law of dam , Sect. 195; Shearman & Redfield
on Neg., Sect. 48.
51. & I, R. R. Co. v. Huffman, 28 Ind. 287.
= \
190 LAW OF DAMAGES.
quires of sober men in the same situation. But we think
that where the defendant is charged with gross negligence, the
fact that the plaintiff was in a helpless condition from the ex-
cessive use of intoxicants, should be considered by the court or
jury trying the cause in arriving at a conclusion as to the de-
gree of negligence that should be attributed to the defendant.
230. Blind, Insane and Foolish Persons. The law respects
human infirmities, and watches with a guardian care over the
person and property of those who are unable to protect them-
selves. And when one’s conduct is called in question it in-
quires into his capacity, in order to measure the degree of care
that he is required to exercise. -And when one is destitute of
the faculty of seeing, or is insane or foolish, he is only required
to exercise the faculties that he has, according to the best. of his
ability. The same degree of care that is required of an infant
in respect to acts of contributory negligence, is applicable to
blind, insane and foolish persons. They are only required to
excrcise the faculties they have.’
231. “The question whether a party has been negligent in
a particular case is one of mingled law and fact. It includes,
indeed, two questions: (1) whether a particular act has been
performed or omitted; (2) whether the performance or omis-
sion of this act wasa breach of legal duty. The first of these
is a pure question of fact; the second, a pure question of law.’?
Thus: :
Il. Cent. v. Hutchinson, 47 Ill, 408; but see Meyer v. Pacific R. Co.,
40 Mo. 151; Field on the law of dam. sect. 198; O'Hagan v. Dillon, 42 N.
Y. Superior Court, 456.
‘Sleeper v. Sandouen, 52 N. H., 244; see ant. page on infants.
Field on the laws of damages, sects. 199-200.
*Shearmon and Redfield on Neg., 11-12; Tarwater v. Hannibal R. Co.,
42 Mo., 193,
-NEGLIGENCE. 191
In the case of Young v. Harney, which was an action
brought to recover damages for the negligent killing of.a horse,
the defendant was the owner of an unenclosed lot, in a suburb
of the city of Indianapolis, near the line of the streets. He
commenced digging a well on his lot, forty-two inches across,
andsunk it tothe depth of six feet, and then abandoned it.
It rerhained a long time in this condition, except that it was
sometimes partially covered over with loose boards, but never
entirely, and most of the time not atall. The holeor pit was
useless. The city of Indianapolis contained about twenty-five
thousand inhabitants. Horses and cattle were permitted to
run at large, by aii order of the Board of Commissioners of the
county, and they were in the habit of grazing in large num-
bers near the defendant’s well. On acertain day the plain-
tiff’s horse fell into the defendant’s well and was killed, andthe
plaintiff brought suit for damages. The cotrt held that the
defendant’s liability depended upon the degree of probability
there was that such accident might happen from thus leaving
exposed the partially dug well, considered in connection with
the usefulness of the act or thing causing the damage. If the
probability was so strong as to make it the duty of the owner
of the lotasa member of the community, to'guard that com-
munity from danger to which the pit exposed it, members in
person and property, he was liable to an action for loss occurring
through his neglect to perform that duty. Held thatthe leav-
ing the well in the condition it was, with the surrounding cir-
cumstances was negligence, and that the defendant was liable.'
232. How a Man Should Use his Own Property. An clemen-
tary principle and one that we have referred to in a former
116 Ind. 314; Durham v. Musselman, 2 Black (Ind.) 96.
Where the defendant cut a tree on his unenclosed land so that it was
nearly ready to fall, and set it on fire, and it fell afterward and killed
plaintiff’s horse, held that defendant was not liable. 2 Black 96.
192 LAW OF DAMAGES.
part of this work, is that a@ man must so “use his own rights and
property as to do no injury to those of his neighbors, for in all civil acts
the law does not so much regard the interest of the actor as the loss and
damages of the party suffering.”? This principle can be applied to
the facts and circumstances of almost every case involving
the question of negligence. It has, therefore, been frequently
held that every person who occupies land, who allows wells or
mining shafts to remain on his land unguarded and unpro-
tected, is responsible in damages to all persons who sustain
injury from falling into them, provided they were lawfully
traversing the land on which the shaft or well existed and fell
into it without negligence or misconduct on their part, but if
they were at the time trespassers on the land they could not
recover.’
233. Negligence Not Imputed to a Person in the Act of Saving
Ife. Where one sees a little child on a railroad track and a
train is rapidly approaching, so that the child unless rescued
would be instantly killed, and he makes an effort to save the
child and rushes upon the track for that purpose and is killed,
the law has such a high regard for. human life that it will not
impute negligence to the deceased, unless made under circum-
stances constituting rashness in the judgment of a prudent
? Saunders’ Negligence, 61; Gagg v. Vetter, 41 Ind. 228.
5 Hardcastle v. the South Yorkshire R. W., 4 H. & N. 67; 28 L. J.
Exch. 137; Blyth v. Topham, 29 L. J. 203; Hounsell v. Snyth, 7 C. B. N.
731; Gantrel v. Egerton, 36 L. J. C. P. 318; Gallagher v. Humphries, 6
Law Times 684; Groveatt v. Williams, 4 Best and S. 149, 82 L. J. Q. B.
237; Holland v. Vince, 10 Met. 371; Bush v. Brainard, 1 Comen. 78; Gagg
v. Vetter, 41 Ind. 228.
When the defendant is liable in the action, the plaintiff was entitled
to recover as a part of his damages compensation for his loss of physical
and mental capacity so far as proved to have been caused solely by the
defendant’s negligence, and the jury must ascertain from the evidence
what injury the plaintiff has sustained. Holyoke vy. G. T. R. R. Co., 48
N. H. 541.
NEGLIGENCE. 198
person, and it is for the jury to say in such case whether the
conduct of the party injured is to be deemed rash and reckless.*
234. Remote Consequences. It is a well settled rule that
every person who does a wrong is responsible for all the mis-
chievous consequences that may reasonably be expected to re-
sult under ordinary circumstances from such misconduct.
When one officiously interferes with or makes use of the prop-
erty of another without his permission, he will be held re-
sponsible for all the consequences of such interference, whether
he intended the injury or not.! Where the consequence of an
unlawful act are immediate, he who does the act is considered
as the active doer of all that directly follows.’ But the general
rule is that the wrong doer will only be held responsible for
the natural and proximate consequence arising from his negli-
gent act, and will not be held for such consequence as could
not have been foreseen by the exercise of due diligence and
reason. He will not be responsible for consequences arising
from a combination of causes or a conjunction of his fault, with
circumstances of an extraordinary nature.’ If the defendant
by his negligent conduct has produced a cause, if uninterfered
-with would harm no one, and a third person or a new inde-
‘Eckert v. Long Island R. Co., 43 N. Y. 502; Youmans vy. Padden, 1
Mich. (N. P.) 127.
A person is not to be charged with negligence because he does not,
when suddenly startled by the cry of danger, do exactly whatone not ex-
posed might think he might or ought to do. I, B. & W. R. Co. v. Carr,
adm., 35 Ind. 510; see Chicago v. Hesing, 83 Tl. 204.
1 Burdock v. Worrell, 4 Barb. 596; Cruft v. Newark, &c., R. Co., 35 N.
Y.17; Wharton on Neg., Sect. 134; Tindle, C. J., in Davis v. Garrett, 6
Bing. 716; Rigley v. Hewett, 5 Exch. 243; Albertson v.Chandle, 11 Mich.
542; Wright v. Gray, 2 Bay 464; Vanderburg v. Truax, 4 Denio 464; Fent
v. T. R. Co., 59 Ill. 49.
? Burdock v. Worrell, 4 Barb. 596; 1 Hillard on Torts, 85; Fairbanks v.
Kerr, 7 Pa. st. 86; Ryan v. N. Y. C.R.R. Co., 30 N. Y. 210.
5 Walrath v. Redfield, 11 Barb. 368; Butler v. Kent, 19 Johnson 223.
194 . LAW OF DAMAGES.
pendent agency intervenes, and by the “conjunction of the two
the plaintiff is injured, there can be no recovery.’
235. The Rule as to the Precised Point Where Pecuniary Re-
sponsibility Ceases Not Definitely Settled. There is quite a conflict
and not a little confusion among the authorities as to the pre-
- cised point at which pecuniary accountability for the conse-
quence of a negligent act is to cease. There has been effort
after effort put forth by the courts of last resort, both in this
country and England, to lay down some definite rule that
would be applicable alike to all cases, but so far they have
only succeeded in laying down a principle that can be applied
with a degree of accuracy to most cases. It is embodied in the
common law maxim, “Causa proxima non remote a spectature,” the
mmediate and not the remote cause is to be considered.* ,
As we have already said the damages: that the plaintiff
can recover must be the natural and proximate consequence
of the act complained of. The difficulty that the courts have
encountered in attempting to establish a general rule is to
draw the line between the proximate and remote consequence.®
It is obvious that in almost every considerable disaster the
result of human agency and dereliction of duty, a train of con-
sequence generally ensues and so ramifies as, more or less, to
affect the whole community. It is clear that indemnity can-
not reach all these results, although parties suffer who are
innocent of blame. This is one of the viccitudes of organized
society, and every person who is a member of society must
take the risk of these viccitudes.’ This is clearly illustrated
5 Cruft v. Newark, &c., R. R. Co., 85 N. Y. 17; Wharton on Neg., 134.
Penn. R. R. Co. v. Kerr, 62 Pa. st. 383; 1 Am. Report 4381.
5 2 Greenleaf evid., Sect. 256.
6 Penn. R. R. Co. v- Kerr, 62 Pa. 353.
"Penn. R. R. Co, v. Kerr, 62 Pa, 353; Report in 1 Am. Report 481.
NEGLIGENCE. 195
by supposing that A owes B five thousand dollars, which he
agrees to pay at a designated time. A fails to pay the money
at the time specified B, by reason of which he is unable to
meet his engagements and is thrown into bankruptcy and
ruined, and many of his creditors are crippled financially.
The result is plainly traceable to the failure of A to pay as he
agreed. But, notwithstanding the fact that B has been ruined
by A’s misconduct, the law in case he is sued would only com-
pel him to pay his debt with interest. “He is not held for
consequences which he had no direct hand in producing and
no reason to expect.” The immediate cause of B’s bankruptcy
was his failure to pay his debts. ‘The cause of the cause was
the failure of A to pay him, but this was the remote cause be-
ing thrown back by the interposition of the proximate cause,
the non-payment of B. of his own debt.”
236. How to Ascertain Whether the Defendant is Liable. The
best way to arrive at a conclusion as to the liability of the
defendant is to ask the question, ‘ Did the cause alleged pro-
duce the effect or injury complained of without another cause
intervening, or was it made to operate only through or by an
intervening cause?” But this test is not perfect, for there are
cases in-which the cause of the disaster, although seemingly
removed from the original cause, are still incapable of being
separated from it. ‘We are inclined to the opinion that the
general rule should be that every defendant should be held
responsible for all those consequences arising naturally, that is
according to the usual course of things or such as might have been fore-
seen and expected as the result of his conduct, and not for those that
arise unusually or which could not have been foreseen and which he was
under no moral obligation to take into consideration.’
11 Penn. R. R. Co. v. Kerr, 62 Pa. 353; 1 American R. 481; | 8 Parson
Cont. 198.
2 2 Parson on Contract, Vol. IT, P. 880.
’ Hadley v. Baxendale, 9 Exch. 341; Pa, R. R. Co. v. Kerr, 353.
196 LAW OF DAMAGES.
Under this rule the first efficient and adequate cause, as
well as every intermediate cause necessarily following from
the first cause, is considered the proximate cause, unless some
new cause independent of the first cause shall intervene be-
tween the first cause and the final injurious result. The prox-
imate and remote cause and effect do not have reference to
time nor distance, nor merely to the succession of events or to
the succession of cause and effect. A wrong-doer is not merely
responsible for the first result of his wrongful act, but he is
also responsible for every succeeding injurious result that
could have been foreseen by the exercise of reasonable dili-
gence, as the reasonable, natural and probable consequence of
his own act. He is held responsible for any number of in-
jurious results consecutively produced by impulsions, one upon
another, and constituting distinct and separate events, pro-
vided they all necessarily follow from the first wrongful cause.
And where any number of causes and effects intervene between
the first wrongful cause and the final injurious consequence,
and if they are such as might with reasonable diligence have
been foreseen, the last result, as well as the first and every in-
termediate result, is to be considered the proximate result of
the first wrongful cause. But the fact should not be over-
looked that if a new cause intervenes that is not the conse-
quence of the first wrongful cause and which is not under the
control of the wrong-doer, or which could not have been fore-
seen by the exercise of reasonable diligence by the defendant —
and except for which the final injurious consequences could
not have happened, then such injurious consequences must be
deemed too remote and there can be no recovery.®
237. The Conflicting Views. We have already referred to
the fact that the authorities are not harmonious upon the
5 A.,T. &S. Fe R. R. Co. v. Standford, 12 Kansas 354; Pa. R. R. Co. v.
Kerr, 62 Pa. 353.
NEGLIGENCE. 197
question of the liability of the wrong-doer for the consequences
of his act. The Supreme Court of the State of Pennsylvania,
in a recent well-considered case, held that where the plaintiff's
warehouse, situated on a railroad, was set on fire by the negli-
gent escape of sparks from the defendant’s locomotive, which
was running on said road, and the burning warehouse com-
municated fire to the plaintifi’s hotel, (situated thirty-nine
feet distance), whereby it was destroyed, the plaintiff could
not recover, as the burning of the hotel was too remote.* In
this decision the Pennsylvania Court follows the decision of
the Court of Appeals of New York, in the case of Ryan v. the
New York Central Railroad Company.°
Those cases have been the subject of much criticism since
they were decided, and it may, perhaps, be doubted whether
they have always been quite understood. If they were in-
tended to assert the doctrine that when a building has been
set on fire through the negligence of a party, and a second
building has been fired from the first, it is'a conclusion of law
that the owner of the second has no recourse to the negligent
wrong-doer, they have not been accepted as authority for such
a doctrine even in the States where the decisions were made.°
And they are certainly in conflict with the weight of
authority." .
In a recent case in the Supreme Court of the United
States in an action to recover compensation for destruction by
4 Penn. R. R. Co. v. Kerr, 62 Pa. st. 353.
5 35 N. Y. 210.
® Pa. RB. RB. Co. v. Hope, 80 Pa. st. 373; Webb v. Watertown & Ogdens-
burg R. R. Co., 49 N. Y. 420.
' Kellogg v. C. & N. W. RB. R. Co., 26 Wis. 224; Perly v. Eastern R. R.
_ Co., 98 Mass. 414; Higgens v. Dewy, 107 Mass. 404; Lent v, T., P. & W.
R. R., 49 Ill. 349.
198 LAW OF DAMAGES.
fire of the plaintiff's saw-mill and a quantity of lumber,
situated and lying in the State of Iowa on the banks of the
Mississippi River, it was admitted that the property was de-
stroyed by fire. The fire was negligently communicated from
the defendant’s steamboat, Jennie Brown, to an elevator built
of pine lumber one hundred and twenty feet high. The
mill stood five hundred and eighty feet from the elevator, and
that the nearest of the plaintiff’s piles of lumber was three
hundred and eighty feet from the elevator. It was claimed by
the defendant that the plaintiff could not recover, as the prox-
imate cause of the burning of the mill and lumber was the
burning of the elevator and the injury was to remote. After
reviewing the authorities the court said: “The true rule is
that what is proximate cause of an injury is ordinarily a
question for the jury. It is not a question of science or of legal
knowledge. It is to be determined as a fact, in view of the
circumstances of facts attending it. The primary cause may
be the proximate cause of the disaster, though it may operate
through successive instruments, as an article at the end of a
chain may be moved by force applied to the other end, that
force being the proximate cause of the movement, or, as in
the oft-cited case of Squib, thrown into the market place.
* * * * * * * * *
The question always is, Was there an- unbroken connection
between the wrongful act and the injury a continuous opera-
tion? Did the fact constitute a continuous succession of events
so linked together as to make a natural whole, or was there
some new and independent cause intervening between the
wrong and the injury? It is admitted that the rule is difficult
of application, but it is generally held that in order to warrant
a finding that negligence or act not amounting to wanton
wrong is the proximate cause of the injury. It must appear
that the injury was the natural and probable consequence of
the negligent or wrongful act, and that it ought to have been
foreseen in the light of attending circumstances. These cir-
NEGLIGENCE. 199
cumstances in a case like the present are the strength and
direction of the wind, the combustible character of the elevator,
its great height, and the proximate and combustible nature of
the saw-mill and the piles of lumber. Most of these circum-
stances were ignored in request for instruction to the jury, yet
it is obvious that the immediate and inseparable consequences
of negligent fire the elevator would have been very difterent if
the wind had been less, if the elevator had been a low build-
ing constructed of stone, if the season had been wet, or if the
lumber and mill had been less combustible. And the de-
fendant might well have anticipated or regarded the probable
consequence as much more far-reaching than would have been
natural or probable in other circumstances. We do not say
that even the natural and probable consequence of a wrongful
act or omission are in all cases to be chargeable to the mis-
feasance or non-feasance. They are not when there is a suffi-
cient and independent cause operating between wrong and in-
jury. In such case the resort of the sufferer must be to the
originator of the intermediate cause. But where there is no
intermediate efficient cause the original wrong must be
considered as reaching to the effect and proximate to it. The
inquiry must, therefore, always be whether there was an in-
termediate cause disconnected from the primary fault and self-
operating which produced the injury. Here lies the difficulty.
But the.inquiry must be answered in accordance with the
common understanding. In a succession of dependent events
an interval may always be seen by an acute mind between a
cause and its effect, though it may be so imperceptible as to
be overlooked by a common mind. Thus, if a building be set
on fire by negligence and an adjoining one be destroyed with-
out any negligence of the occupant of the first, no one would
doubt that the destruction of the second was due to the negli-
gence that caused the burning of the first. The same might
be said of the burning of the furniture in the first. Such re-
finements are too minute for rules of social conduct. In the
200 LAW OF DAMAGES.
nature of things there is in every transaction a succession of
events more or less dependent upon those preceding, and it is
the province of a jury to look at this succession of events or
facts and ascertain whether they are naturally and probably
connected with each other by a continuous sequence or are
disserved by new and indepentlent agencies, and this must be
determined in view of the circumstances existing at the
time.” The finding for the plaintiff in the court below was
confirmed.
In a recent case in California, where sparks from the de-
fendant’s locomotive set fire to cut and dried grass and weeds
which the Railroad Company had permitted to lie in a com-
bustible state upon its land along the track and the fire was
communicated thence to an adjoining field and through stub-
ble and uncut, but dry, grass to a wheat stack, which was thus
consumed, it was held that the defendant was liable? It was
also held by the Supreme Court of the State of Wisconsin in
1870 that where fire caused by sparks from the engine used by
a Railroad Company were communicated to the land of an ad-
joining owner by means of dry grass,weeds and bushes allowed
to accumulate along the line of the track, that the defendant
‘ Milwaukee, &c., R. R. Co. v. Kellogg, 94 U. S. Report 469.
The general rule of damages for tortious acts is this: One who com-
mits such an act is liable for the injury which is the natural and proba-
ble consequence of his misconduct. He is liable not only for those in-
juries which are caused directly or immediately by his act, but also for
each consequential injuries as, according to the common experience of
men, are likely to result from it. Nor is he exhonerated from liability
by the fact that intervening events or agencies, such as according to
common experience and the usual course of events might reasonably be
anticipated. Derry v. Fletner, 118 Mass. 131; Propeller Mont. ed. v.
Mallison, 17 How. 252; Perely v. East R. R. Co., 98 Mass. 414.
2A.,T. &8. F. R. R. Co. v. Standford, 12 Kansas 354; 15 Am. R. 362;
Flynn v. 8. F. & 8. J. R. R. Co., 40 Col. 14; Milwaukee, &c. R R. Co. v.
Kellogg, 94 U. 8. (4 Otto) 469.
NEGLIGENCE. 201
was liable, and that the fact that the property destroyed was
at adistance from the place where the fire originated, did not
affect the question of the liability of the company or render
the fire the remote and not the proximate cause of the injury.’
238. The Measure of Damages. The liability of the defen-
dant for damages in case of tortious negligence is broader than
in an action on contract. The amount of recovery will vary
with the circumstances of each case. But the defendant will
be held responsible not only for all the damages which a pru-
dent man would expect to result from his fault, but also for all
that a prudent man would anticipate as a possible consequence
thereof, and where the amount of damages cannot be accurately
determined the law compels the wrong-doer to bear the
burthen of such difficulty, and where there is no preponderance
of evidence on either side in favor of one of two or more
amounts he must pay the largest sum.*
239. The Proximate Consequences. The defendant will be
held responsible for all the proximate consequences of his act
or default. But courts have found great difficulty in drawing
the litte between the proximate and remote causes. But this
difficulty can he obviated to some extent by considering the
first efficient and adequate cause, as well as the intermediate
causes necessarily following from the first cause as the proxi-
mate cause, unless seme new cause independent of the first
3 Kellogg v. the C. & N. W. R. Co., 26 Wis. 223.
The defendant put a dangerous spike hurdle on a private road over
which he and others had a right of way. Some person without the
knowledge of the defendant moved the hurdle a few yards. On a dark
night the plaintiff, who was not a trespasser, without negligence and
thinking to avoid the original position of the hurdle, came into collision
with it and was injured Held, that the plaintiff could recover. Man-
gan v. Alterton, 4 H. & C. 388, L. R. 1 Ex. 239.
4 Shearman & Redfield on Neg., S. 594; Leeds v. Amherst, 20 Bean 239,
\
202 LAW OF DAMAGES.
cause shall intervene between the first cause and the final
injurious result.’
240. Prospective Damages. It is well settled that the
plaintiff is entitled to recover one compensation for all his in-
juries, past and prospective, in consequence of the defendant’s
wrongful acts. But damages for future suffering must be lim-
ited to such as would result with reasonable certainty from
the injury complained of—a mere probable injury is not
enough.® /
241. Element of Damages that May be Recovered in Case of a
Personal Injury. Expense of nursing ; medical expense ; loss of
time during disability ; loss of both bodily and mental powers,
or for actual suffering both of body and mind.”
5A.7T.&S F.R R Co. v. Standford, 12 Kansas 354; 15 Am. R. 362;
Milwaukee, &c., R. R. Co. v. Kellogg, 94 U. S. 469; Shearman & Redfield
on Neg., 679; See -anti-page of this chapter under the head of remote
conseqnences.
6 Fry v. Dubuvue & § R. R. Co., 45 Iowa 416; Curtis v. Rochester, 18
N. Y. 534; Fulsom v. Concord, 46 Vt. 135; Holyoke v. Grand Trunk R.
Co., 48 N. H. 541; Lindsy v. Town of Danville, 46 Vt. 144; Nones v.
Northouse, 46 Vt. 587; Kerr v. Forque, 54 Ill. 482; Shearman & Redfield
on Neg., Sect. 595-596; Topeka v. Tuttle, 5 Kansas 312-425; Daily v. Dis-
mal Swamp Canal Co., 2 Ired (N. C.) law 222; Peoria Bridge Asso. v.
Looms, 20 Ill. 235; Frink v. Schroyer, 18 Ill. 416; Memphis, &c., R. R. Co.
v. Whitfield, 44 Miss. 466; Spicer v. C.& N. W. R. R. Co., 29 Wis. 580.
In actions on the case, unless the injury complained of be of such a
nature that actions can continually be brought from time to time, the
jury may assess all the damages the plaintiff has sustained up to the
time of the trial. They are not confined to damages sustained previous
to the date of the writ. Daily v. Dismal Swamp Canal Co., 2 Ired (N.
C.) law 222.
A jury in assessing damazes against a railroad corporation for an in-
jury occasioned hy its neglect, may take into consideration any promi-
nent damage which the evidence shows in the nature of a consequential
injury. Peoria Bridge Asso. v. Looms, 20 Ill. 235, 18 Ill. 416.
"Holyoke v. G. T. R.Co., 48 N. H. 541; Hopkins v. Atlantic & St.
NEGLIGENCE. : 203
242. Damages in Case of Personal Injury. The damages
should embrace indemnity for medical expense; also loss of
time or loss from inability to perform ordinary labor, or
capacity to earn money; the reasonable satisfaction for loss of
both bodily and mental powers, or for actual suffering both of
body and mind, which are shown to be the immediate and
necessary consequence of the injury wrongfully received, and
in case of willful injury exemplary damages are some times
added.’
Lawrence R R. Co., 36 N. H. 14; Shaw v. B. & W. BR. R. Co., 8 Gray 28;
Ransom v. N. E. R. R. Co., 15 N. Y. 415; Thebold v. the Railway Pass
Insur. Co., 26 Eng. Com. Law and Eng. Report, 482; 18 Adolphus &
Ellis Rep., N. S. 93; Blake v. the Midland R. R. Co., 10 Eng. Law and
Eng. Rep. 437; Lindsy v. Bushnell, 15 Conn. 290; Canning v. Williams-
town, 1 Cush. 451; Lincoln v. 8.S. R. R. Co., 28 Wend. 425; Segar v. the
Town of Barhamstead, 22 Conn. 290; Cadwell v. Murphy, 1 Duer. 233;
Perkins v. Concord R. R. Co., 44 'N. H. 155; Peoria Bridge Asso. v.
Looms, 20 Ill. 235; Barksley v. Swan, 4 McLain 333; Moody v. Osgood, 50
Barb. 628; Wade v. Leroy, 20 How. (U. S.) 34; Morse v. Auburn, &c., R.
Co., 10 Barb. 621.
1In an action for damages for personal injuries the amount of the
award for loss of power to earn money and fer pain and anguish suffered
by reason of the injury, rests with the discretion of the jury. Morris v.
Chicago, &c., R. R. Co., 45 Iowa 29; Indianapolis v Gaston, 58 Ind. 224;
2 Greenleaf evid., S. 267; Cox v. Vanderleed, 21 Ind. 164; Hendrickson v.
Kingsbury, 21 Ia. 379; Wily v. Keokuk, 6 Kansas 94, Holyoke v. G. T,
R. R. Co., 48 N. H. 541; Hopkins v. the Atlantic & St. Law. R. R. Co., 36
N. H. 14; Shaw v. the Boston & Wore. R. R. Co , 8 Gray 82; Ransom v.
the N. Y.& E k. R. Co., 15 N. Y., 415; Thebold v. R. R. Pass. Ins. Co.,
26 Eng. L. & E. 432; 18 Adolphus & Ellis, N. 8. 93; Blake v. Midland R.
R.Co,10E.L & Eng. R. 437; Lindsly v. Bushnell, 15 Conn. 225, Segar
v. Town of Barkhamstead, 22 Conn. R. 290; Canning v. Williamstown, 1
Cush. 451; Lincoln v faratoga & Sch. R. R. 23 Wend. 425; Cadwell v.
Murphy, 1 Duer. 233; Perkins v. Concord, 44 N. H. 155; Taber v. Hud-
son, 5 Ind. 322.
In case of a personal injury the plaintiff can recover for the bodily in-
juries sustained, the pain undergone, the effect on the health of the suf.
ferer according to its degree and its probable duration as likely to be
temporary or permanent, the expense incidental to attempts to effect a
‘cure or to lessen the amount of injury, the pecuniary loss sustained
through inability to attend to professional business, which again may be
a temporary character or may incapacitate the party for the remainder
XV
204 LAW OF DAMAGES.
248. The Jury Should Consider all the Facts. The general
rule in all cases of torts is redress commensurate with the in-
jury complained of. In ascertaining its extent the jury should
consider all the facts that relate to wrongful acts of the defend-
ant and its consequences to the plaintiff, but they are not at
liberty to go farther, unless the act was done willfully, or was
the result of that reckless indifference to the rights of others
which is equivalent to an intentional violation of them. In
that case the jury, in some states, are authorized, for the sake
of public example, to give such additional damages as the cir-
cumstances require. The tort is aggravated by evil motives.
On this rests the rule of exemplary damages.’
244 The Rule for the Assessment of Damages in Cases of Injury
to Real and Personal Property. There are principles of natural
justice the application of which the amount that the in-
jured party ought to recover, may in all cases be readily and
certainly determined, and it is that the owner, to whom the
compensation is due, must be fully indemnified, and that the
wrong-doer must not be permitted to derive any benefit or ad-
vantage whatevecrfrom his wrongful act. The injured party
must be placed in the same situation in which he would have
been had the wrong not been committed or had it been in-
stantly repaired by the payment of the compensation then
due. As the actual loss to the owner is the same whether the
injury arise out of trespass or omission of duty, the rule of com-
plete compensation in both classes of cases should be the rule
for the assessment of damages. As has already been said, in
of his life. Phillips v. L. & South W. Co., No. 7 Cent. Law Journal of
August 15, 1879, page 125,
? Milwaukee & St. Paul R. R. Co. v. Arms, 91 U.S. stat., 489; Day v
Woodworth, 13 How., 371; Baltimore R. R. Co. v. Quigley, 21 How. 213;
Suydam v. Jenkins, 3 (Sandford) N. Y. Superior Court, 641.
‘Suydam v. Jenkins (3 Sandford) N. Y. Superior Court, 641.
An amount sufficient to indemnify the party injured for the loss which
NEGLIGENCE. 205
aggravated cases of torts, exemplary damages are sometimes
added.
245. Damages to Real Estate. The general principle of full
compensation for actual loss sustained, which we havercferred
to as applicable in assessing damages generally in actions of
tort, are applicable in cases of negligence, whether of miss-
feasance or non-feasance. Therefore, in case of injury by neg-
ligence to real property, the ordinary rule of damages is the
difterence between the market value of the property immedi-
ately before, and its like value immediately after the injury oc-
curred.* This, however, is not a universal rule. Sometimes,
where the injury can be repaired at a slight expense, that ex-
pense will be taken as the measure of damages. And in case
of injury, to fruit, shade, or ornamental treess, destroyed or in-
jured, the value of the tree, or damages for the injury may be
assessed apart from the land.’
&
246. Personal Property— Damages. For injury to personal
property by negligence, the same old rule of full compensation
for all injuries, to which we have prequently referred in
treating of the measure of damages in cases of torts, applies.
If the property is entirely destroyed, the owner is entitled to
its full value. But in case of aninjury not resulting in its de-
2
is the natural reasonable and proximate result of the wrongful act com-
plained of, and which a proper degree of prudence on the part of the
plaintiff would not have averted, is the measure of damages which the
jury are usually instructed to assess except in cases where exemplary
damages are allowable.
Baker v. Draker, et al.,53 N. Y., 211; see Whecland y. Lynch, 60 N.
Y., 469; Kimmel v. Stone, 6 Hiersis, 157; Harrison vy. Harrison, 1 C. & P.
412; Vaughan v. Wood; 1 Mylne & Keem, 403.
4 Field on the law of dam., 536, sect. 669; Terry v. Mayor, etc., of N. Y
8 Bosw., 504: see anti-page under head of trespass.
5 Whitelue v. N. Y. Cent, R. R, Co., 36 Barb., 644.
206 LAW OF DAMAGES.
struction, its value immediately before ani again im-
mediately after the injury usually furnishes ‘h+ meu.sure
of damages. And in case the property injured is a do-
m2stic animal the owner should be remunerated for any
reasonable care bestowed upon it in endeavoring to restore it,
in addition to their depreciated value by reason of the injury.
And in some cases allowances have been made for expense in-
curred in searching for animas when they have strayed and
become lost by the negligence of the defendant.®
247. Malpractice. At common law, an action can be
brought and maintained against a physician or surgeon for an
injury growing out of a want of skill, or for negligence in
treating a patient.2 The law requires persons engaged in the
practice of medicine or surgery to possess a certain amount of
skill. But it sets up no arbitrary standard by which their
skill is to be tested. It judges of that by the surrounding cir-
cumstances. The advanced state of the profession and im-
provements are always considered: in determining the skill
of the physician or surgeon. And afterall the facts have been
considered, if the defendant has failed to exercise such skill
and diligence as is ordinarily exercised by the members of his
profession as a whole he will be responsible in damages.
® Field on law of wlam., sect. 670; Watson v. Lisborn Bridge Co., 14
Me., 201. The whole sum recovered cannot exceed the value of the an-
imal. Gillet v. West. R. R. Co., 8 Allen, 560.
* Smothers v. Hanks, 34 Ia., 286; 11 Am. R. 141; Shearman and Red-
field on Neg., s. 436, p. 491; Landon v. Humphries, 9 Conn. 209; How-
ard v. Groves, 28 Me., 97; Wood v. Clapp, 4 Sneed, 65; Renolds v.
Grover, 3 Wis., 416; Richey v. West, 23 Ill., 385; Simond y. Henry, 39
Me., 155; Gramm y. Brewer, 56 Ind., 497; Galliger ‘v. Thompson,
Wright, 456.
Howard v. Grover, 28 Me , 97; Wood v. Clapp, 4 Sneed, 65; Long v
Morrison, 14 Ind., 595; Patton v. Wiggin, 51 Me., 595.
NEGLIGENCE. 207
249. The Damages. The measure of damages in case of an
injury not resulting in death is complete compensation for the
loss and suffering the plaintiff has sustained. The element
to be considered in making the estimate of the plaintiff’s
damages are: 1. The loss of time. 2. All necessary expenses.
8. Suffering of mind and body. 4. Permanent injury, such as
disability to labor or pursue his usual avocation, or prospect-
ive damages.
3 Peoria Bridge Ass. v Loomis, 20 IIL, 235; Caning v. Williamstown, 1
Cush., 451; Ballou v. Farmer, 11 Allen; 73; Cents v. Rochester, et al. RB.
Co., 20 Barb. 282; Hopkins v. Atlas R Co, 37 N.H, 9; Wade v, Leroy,
20 How. 34; Oakland R. Co. v. Field, 48 Pa. st. 320; Fink v. Scroyer, 18
Til., 416; Hunt v Hoyt, 20 Tl, 544; Murphy R. R. Co. v. Whitfield, 44
Miss, 466; 40 N. Y., 9; Hanover v. Coyle; 55 Pa. st. 396; Long v.
Morrison, 14 Ind., 595; Conner v. Weston, 8 Ind., 315; Lee v. Spears, 17
Ind.; 114; Hill on Torts, 224-225; McCandless v. McWha, 22 Pa. st., 261;
State v. Baker, 2 Wis., 259; Simonds v. Henry, 39 Maine, 155; 43 Ind.,
343; 46Ind., 160.
CHAPTER AIL
INJURY RESULTING IN DEATH.
Tur Common Law DID Not ConsIDER DEATH AN InJuRy. Lorp
' CaMPBELL’s acT. THE New YorK STATUTE. THE STATUTES
OF THE DIFFERENT STATES DO NOT DIFFER’ MATERIALLY FROM
THE New Yorx«K sTaTUTES. THE THEORY OF THE STATUTES.
THE DAMAGES, ACTUAL AND PECUNIARY LIABILITY. NotTH-
ING ALLOWED FUR PHYSICAL AND MENTAL SUFFERING. Dam-
AGES FREQUENTLY LIMITED BY THE STATUTE.
250. The Common Law Rule. The rules of the common
law are based on a few broad and comprehensive principles of
natural right and justice, and it was framed for the purpose of
giving each person a remedy for every injury received by the
negligent or wrongful act of another. But, notwithstanding
its sweeping provisions, it was held at an early day that the
death of a human being cannot be complained of as an injury.?
But we are much inclined to criticise this construction of the
1 Lord Ellenborough in Baker v. Bolton, 1 Camp’ 493; Cary v. Berk-
shire, &c., R Co, 1 Cush. 475; Hyatt v. Adams, 16 Mich. 180; Edon v.
Lexington R. R. Co., 14 B. Mon. 20; Hill on Torts, 83.
INJURY RESULTING IN DEATH. 209
rules of the common law, because it ignores the natural rela-
tions. If a child that is unable to take care of itself is the
owner of a small amount of personal property, and that prop-
erty is injured by the wrongful act of another, the law gives
it a remedy, but if some one by a negligent or willful act takes
the life of both of its parents and leaves it poor and unable to
support itself, it has no remedy. In this instance the law
recognizes a little minor injury that only results in the loss of
afew dollars and ignores the loss of parental care and training
and the duty and ability of the parent to supply the physical
wants of their child. This looks so unreasonable that it is
hard to believe that it was ever the rule of the ancient
genuine common law, but this defect, if it is a defect, has
been supplied by legislative enactment in England and in
most, if not all, of the States.
251. Lord Campbell’s Act. The British Parliament in 1846
passed what is known as Lord Campbell’s act, which pro-
vides: “Section 1. Whensoever the death of a person shall
be caused by the wrongful act, negligence or default, and the
act, neglect or default is such as would, if death had not en-
sued, have entitled the party injured to maintain an action
and recover damages in respect thereof, then in every such
.case the person who would have been liable, if death had not
ensued, shall be liable to an action for damages, notwithstand-
ing the death shall have been caused under such circumstances
as amounts in law toa felony. Section 2. Every such action.
shall be for the benefit of the wife, husband, parent and child
2 Shearman v. the. Western Stage'Co., 24 lowa 543; Ford v. Monroe,
20 Wend. 210; Boston, &c., v. Dana, 1 Gray 83; Drew v. the Sixth Ave-
nue R Co., 26 N. Y. 49; Donaldson v the Mississippi, &c , R. Co., 18 Ia.
280; 1 Cent. Law Journal, 595; Jones v. Perry, 2 Esp. 482; Cross v. Guth-
rey, 2 Root (Conn.) 90; discussion of question in 1 Central Law Journal
590, 614, 622, 1247.
210 LAW OF DAMAGES.
of the person whose death shall be so caused, and shall be
brought by and in the name of the executor or administrator
of the person of the deceased, and in every such action the
jury may give such damages as they may think proportioned
to the injury resulting from such death to the parties, respec-
tively, for whose benefit such action shall be brought, and the ,
amount so recovered shall be divided among the before men-
tioned parties in such shares as the jury by their verdict shall
find and direct.”"
252. ‘The Statuteof New York. The New York statute pro-
vides as follows: “Whenever the death of a person shall be
caused by a wrongful act, neglect or default, and the act, neg-
lect or default is such as would, if death had not ensued, have
entitled the party injured to maintain an action and recover
damages in respect thereof then, and in any such case the per-
son who, or the corporation which, would have been liable if
death had not ensued, shall be liable to an action for damages
notwithstanding the death of the person injured, and although,
the death shall have been caused under such circumstances as
amount in law to afelony. Every such action shall be brought
by and in the name of the personal representative of the de-
ceased person, and the amount recovered in any such action
shall be for the exclusive benefit of the widow, and next of
kin of such deceased person.”
253. The statutes of the majority of the states do not
differ materially from the New York statute on this subject,.
19 and 10 Vt., chap. 93, sect. 2.
*.N. Y. statute, 1847, chapt. 450, sect. 1 and 2.
Indiana statute: Where the death of one is caused by the wrong-
ful act or omission of another, the personal representative of the former
may maintain an action thereof against the latter if the former, had he
‘
INJURY RESULTING IN DEATH. 211
except, perhaps, in some the amount of the recovery is lim-
ited. We give in our notes a copy of the statutes of several of
the States upon this subject.
lived, might have maintained an action for the same act or omission.
The action must be commenced within two years. The damages cannot
exceed five thousand dollars, and must inure to the exclusive benefit of
the widow and children, and next of kin, to be distributed in the same
manner as personal property of deceased. 2 Davis rev. st., p. 309, sec. 784.
Vermont: Whenever the death of a person shall hereafter be caused
by the wrongful act, neglect or default of any person either natural or
artificial, and the act, neglect or default is such as would, if death had
not ensued, have entitled the party injured to maintain an action and
recover damages in respect thereof, then and in every such case the per-
son or corporation who would have been liable to such action, if death
had not ensued, shall be liable to an action for damages, notwithstand-
ing the death of the persons, and, although the death shall have been
caused under such circumstances, as shall amount in law toa felon.
Every such action shall be brought in the name of the personal repre-
sentative of such deceased person, and the amount recovered in such
action shall be for the exclusive benefit of the widow and next of kin
of such deceased person, who shall receive the same proportion as pro-
vided by law for the distribution of the personal estate of a person dying
intestate. Genl. statute of Vt., 1863, chap. 15, sects. 15 and 16.
New Jersey: Whenever the death of a person shall be caused by the
wrongful act, neglect or default, and the act, neglect or default is such as
would, if death had not ensued, entitle the party injured to maintain
‘an action and recover damages in respect thereof, then and in every
such case the person who, or the corporation which would have been
liable if death had not ensued, shall be liable to an action for damages,
- notwithstanding the death of the person injured, although the death
shall have been caused under such circumstances as amounts in law to
afelon. Every such action shall be brought by and in the name of the
personal representative of such deceased person, and the amount re-
covered in every such action shall be for the exclusive benefit of the
widow and next of kin of such deceased person, and shall be distributed
to such widow and next of kin in the proportion provided by law. In
the relation to the distribution of persoual property left by a person dy-
212 LAW OF DAMAGES.
254. The Theory of the Statute. The theory of the statute
is that the next of kin have a pecuniary interest in the
ing intestate, and every such action, the jury may give such damages as
they shall deem fair and just, with reference to the pecuniary injury re-
sulting from such death to wife and next of kin of such deceased person,
provided that every such action shall be commenced within twelve cal-
endar months after the date of such deceased person.” Nixon digest, p.
234, sects. 1 and 2.
North Carolina: Whenever the death of a person shall be caused by
the negligence or default of any railroad or steamboat company, or any
steamboat or stage coach proprietor in this State, and the neglect or de-
‘fault is such as would have entitled the party injured to maintain an ac-
tion and recover damages in respect thereof, if death had not ensued,
then and in every such case the corporation which would have been lia-
ble, if death had not ensued, shall be liable to an action for damages,
notwithstanding the death of the party injured. Whenever the death of
a person shall be caused by the wrongful act of another person, and the
wrongful act is such as would have entitled the party injured to main-
tain an action and recover damages in respect thereof, if death had not
ensued, then and in every such case the person who would have been
liable, if death had not ensued, shall be liable to an action for damages,
notwithstanding the death of the person, although the death shall have
been caused, under such circumstances, as amount in law to a felony.
Every such action shall be brought by and in the name of the personal
representative of the deceased, and the amount recovered shall be dis-
posed of according to the statute for distribution of personal property in
case of intestacy. And in every such action the jury may give such
damages as they shall deem fair and just, with reference to the pecuniary
injury resulting from such death. * * * The amount recovered in
every such action shall be for the exclusive and sole benefit of the widow
and the issue of the deceased in all cases where they are surviving.” N.
-C. Rew. Code, 1855, p. 65, chap. 1, sects. 8 and 9.
Ohio: Whenever the death of a person shall be caused by the
wrongful act, or neglect, or default is as would (if death had not ensued)
have entitled the party injured to maintain an action and recover dam-
ages in respect thereof, then, and in every such case, the person who,-or
the corporation which, would have been liable if death had not ensued,
INJURY RESULTING IN DEATH. 218
life of the person killed, and the value of this injury is the
shall be liable to an action for damages, notwithstanding the death of
the person injured, and although death shall have been caused under
such circumstances as amount in law to murder in the first or second
degrees, or to manslaughter. Every such action shall be brought by and
in the name of the personal representative of such deceased person, dy-
ing intestate, and the amount of recovery inany such action shall be for
the exelusive benefit of the widow and next of kin of such deceased
person, and the amount of recovery in any such action, the jury may
give such damages as they may deem just, not exceeding five thousand
dollars, with reference to the pecuniary interest. resulting from such
death to the wife and next of kin of such deceased person, provided
that any sucb action shall be commenced within two years after the
death of such deceased person. Swan & Cr., rev. stat. 1139, chap. 87,
8. 636-637.
The statutes of Illinois and Michigan are substatially copies of the
Ohio statute. Ill. rev. 1874, p, 582; 1 Ill. rev. 1858, p, 422,s. 1-2. The
Michigan statute limits the damages to five thousand dollars. Compiled
laws (Duy) 1872, p, 1881.
California: When the death of a person is caused by the wrongful
act or neglect of another, his heirs or personal representatives may
maintain an action for damages against the person causing the death of
a person is caused by an injury received in falling through an opening
or defective place in a sidewalk, street, alley, square or wharf, his heirs
or personal representatives may maintain an action against the person
whose duty it was at the time the injury to have kept in repair such
sidewalk or other place. In any such action the jury may give such
damages, pecuniary or exemplary, as under all the circumstances of the
case may to them seem just. Code of civil prac., 8, 377
Wisconsin: The Wisconsin statute is an exact copy of the Ohio stat-
ute, sec. 12, except the last clause in relation to murder and manslaugh-
ter. Section 13 provides: ‘“Every such action shall be brought by and
.in the name of the personal representative of such deceased person, and
the amount recovered shall belong to and, be paid over to the husband
or widow of such deceased person, if such relatives survive him or her,
but if no husband or widow survives the deceased, the amount recov-
ered shall be paid over to his or her lineal ancestors in default of such
214 LAW OF DAMAGES.
amount for which the jury are to give the verdict. Neither
decedents In any such action the jury may give such damages, not
exceeding five thousand dollars, as they shall deem fair and just. in ref-
erence to the pecuniary injury resulting from such death, to the rela-
tives of the deceased specified in this section, provided any such action
shall be commenced within two years after the death of such deceased
person. Rev. stat. (Taylor) 1858, p. 800, ch. 135, sec. 12-13.
Oregon: When the death of a person is caused by the wrongful act or
omission of another, the, personal representative of the former may
maintain an action at law therefor against the latter, if the former might
have maintained an action had he lived against the latter for an injury
done by the same act or omission. Such action shall be commenced
within two years after the death, and the damages therein shall not ex-
ceed five thousand dollars, and the amount recovered shall be adminis-
tered as other personal property of the deceased person. Oregon code,
1862, sec. 367, gen law, 1872, p. 187.
Missouri: Whenever the death of a person shall be caused by a wrong-
ful act, neglect or default, and the act, neglect or default is such as would,
if death had not ensued, have entitled the party injured to maintain an
action and recover damages in respect thereof, then, and in any such
case, the person who, or the corporation which, would have been liable
if death had not ensued, shall be liable to an action for damages, not-
withstanding the death of the person injured. Gen. stat. of Mo., sect. 2,
chap. .147, Wag st., p. 528. All damages accruing under the last prece-
ding section shall be sued for and recovered: First, by the husband or
wife of the deceased; or second, if there be no husband or wife, or he or
she fails to sue within six months after such death, then by the minor
child or children of the deceased, or third, if such deceased be a minor
and unmarried, then by the father and mother who may join in the suit
and each shall have an equal interest in the judgment, or if either of
them be dead, then by the survivor. * * And in any such action
the jury may give damages as they may deem fair and just, not exceed-
ing five thousand dollars, with reference to the necessary injury result-,
ing from such death to the surviving parties who may be entitled to sue,
and also having regard to the mitigating or aggravating circumstances
attending the wrongful act, neglect or default. Wag st., 519.
Minnesota: Where death is caused by the wrongful act or omission
INJURY RESULTING IN DEATH. 215
the personal wrong or the outrage to the deceased, nor the
of any party the personal representative of the deceased may maintain
an action if he might have maintained an action had he lived for an in-
jury caused by the same act or omission, but the action shall be com-
menced within two years after the act or omission by which the death
was caused. The damages thereon cannot exceed five thousand dollars,
and the amount recovered to be for the exclusive benefit of the widow
and next of kin, to be distributed to them in the same proportion as the
personal property of a deceased person. Rev. st. of Minn., 1866, chap,
77, s. 2; Bliss stat. at large, 1873, p. 913,s. 25; Butler v. Steamboat Mil-
waukee, 8 Minn., 97.
Kansas: When the death, if one is caused by the wrongful act or
omission of another, the personal representatives of the former may
maintain an action, therefore, against the latter, if the former might
have maintained an action had he lived against the latter for an injury
for the same act or omission. The action must be commenced within
two years. The damages cannot exceed ten thousand dollars, and must
inure to the exclusive benefit of the widow and children, if any, or next
of kin, to be distributed in the same manner as the personal property of
the deceased. Kansas Gen. Stat., 1868, p. 799, chap. 80, sec. 422.
Alabama: When the death of a person is caused by the wrongful act
or omission of another, the personal representative of the former may
maintain an action against the latter at any time within one year there-
after, if the former could have maintained an-action had he lived against
the latter for an injury for the act or omission had it failed to produce
death. Rev. Code, Ala., 1867, sec. 2297. The damages recovered in
such action cannot exceed three years’ income of the deceased, and in
no case exceed three thousand dollars. The amount recovered is for
the benefit of the widow; if there be none, then for the benefit of the
child or children ; if there be none, then to be distributed as other per-
sonal property among the next of kin of the deceased. Ibid 2298.
Mississippi : Whenever the death of any person shall be caused by
such wrongful or negligent act or omission as would, if death had not
ensued, have entitled the party injured or damaged thereby to maintain
an action and recover damages in respect thereof, and such deceased
person shall have left a widow or children, or both, or husband or father,
the person or corporation, or both, that would have been liable, if death
916 LAW OF DAMAGES,
s
pain and suffering he may have endured, nor the pain and
had not ensued, and the personal representative of such person shall be
liable for damages, notwithstanding the death and the action may be
brought in the name of the widow for the death of her husband, or by
the husband for the death of his wife, or by a parent for the death of the
child, or in the name of a child for the death of an only parent, the
damages to be for such widow, husband or child, except that in case the
widow should have children, the damages shall be distributed as per-
sonal property of the husband. Rev. Code, 1851, p. 486, sec. 48.
Iowa: Every corporation operating a railway shall be liable for all
damages sustained by any person, including employes of such corpora-
tion, in consequence of the neglect of the agent or by mismanagement of
the engineer or other employes of the corporation. In consequence of the
willful wrong, whether of commission or omission of such agent, engineer
or other employes, when such wrongs are in a manner connected with
the use and operation of any railway on or about which they shall be
employed, no contract which restricts such liability shall be legal or
binding. Iowa Code, I873, sec. 1307.
Arkansas: For wrong done to person or property of another, an ac-
tion may be maintained against the wrong-doer, and such action may be
brought by the person injured, or after his death by his executor or ad-
ministrator against ‘such wrong-doer, or after his death against his ex-
ecutor or administrator in the same manner and with like effect in all
respects as actions founded on contract. State of Arkansas, 1859, p. 120,
chap. 4, sec. 28.
Louisiana: Every act whatever of a man that causes damages to an-
other obliges him by whose fault it happened to repair it. The right of
this action shall survive in case of death in favor of the minor children
and widow of the deceased, or either of them, and in default of these in
favor of the surviving father and mother, or either of them, for the space
of one year from the death. Res st. Louisiana, 1857, sec 18.
Maryland: Whenever the death of a person shall be caused by.
wrongful act, neglect or default, and the act, neglect or default is such as
would, if death had not ensued. have entitled the party iniured to main-
tain an action and recover damages in respect thereof, the person who
would have been liable, if death had not ensued, shall be liable to an ac-
tion for damages, notwithstanding the death shall have been caused.
INJURY RESULTING IN DEATH, . 217
suffering of the claimant on account of the death of the de-
under such circumstances as amount in law to felony. Code Maryland,
1860, article 65, sec. 1, p.449. Every such action shall be for the wile,
husband, parent and child of the person whose death shall have been go
caused and shall be brought by and in the name of the State of Mary-
land for the use of the person entitled to damages, and in every such ac-
tion the jury may give such damages as they may think proportioned to
the injury resulting from such death to the parties, respectively, for
whom and for whose benefit such action shall be brought, and the
amount so recovered, after deducting the cost not recovered from the de-
fendant, shall be divided among the above named parties in such shares
as the jury, by their verdict, shall find and direct, (Id., Sec. 2.)
Pennsylvania: Whenever death shall be occasioned by unlawful vio-
lence or negligence, and no suit for damage be brought by the ‘injured
party during his or her life, the widow of any such deceased or, if there
be no widow, the personal representative may maintain an action for
and recover damage for the death thus occasioned. Purdon’s Penn.
dig., 1862, p. 754, sec. 2. The person entitled to recover damage for an
injury causing death, shall be the husband, widow, children or parent of
the deceased, and no other relative, and the sum shall go to them in the
proportion they would take his or her personal estate in case of intestacy
and that without liability to creditors. (Id, Sec. 3.)
Kentucky: The widow and minor child or children, or either or any
of them, of a person killed by the careless or wanton use of fire arms or
other deadly weapons not in self-defense, may have an action against the
person or persons who committed the killing and all others aiding or
promoting the killing, or any one or more of them for reparation of the
injury, and in such action the jury may give vindictive damages. Gen.
laws of Ky., 1866, App. p. 681.
Maine: Any railroad corporation by whose negligence or careless-
ness, or by that of its servants or agents while employed in its business,
the life of any person in the exercise of due care and diligence is lost,
forfeits not less than five hundred dollars for more than five thousand
dollars to be recovered by. indictment, found within one year, wholly to
the use of his widow, if no children, and to the children if no widow; if
both, to her and them equally ; if neither, to his heirs. Res. stat., 1857,
p. 370, chap. 51, sec. 42. The provisions are also made applicable to
218 : LAW OF DAMAGES.
ceased, are to be taken into an account. These would be the
steamboats, stage coaches and common carriers. Id., p. 376, chap. 52,
sec.97.
New Hampshire: If the life of any person not in their employment
shall be lost by reason of the negligence or carelessness of their servants
or agents in this State, such proprietors shall be fined not exceeding five
thousand nor less than five hundred dollars, and one-half of such fine
shall go to the widow and the other half to the children of the deceased.
If there is no child the whole shall goto the widow, and ifno widow to his
heirs, according to the law regulating the distribution of intestate estate.
Gen. stat. N. H., 1867, p. 529, chap. 264, sec. 14.
Connecticut: If the life of any person being on a passing or crossing
upon a public highway, in the exercise of reasonable care, shall be lost
by reason of the negligence or carelessness of any railroad company in
this State, or by the unfitness or negligence or carelessness of its servants
or agents, such railroad company shall be liable to pay damage not ex-
ceeding five thousand dollars nor less than one thousand dollars to the
use of the executor or administrator, in an action on the case upon this
statute, for, the benefit of the husband or widow and heirs of the de-
ceased person. One moiety thereof shall go to the husband or widow,
the other to the children of the deceased, but it there shall be no chil-
dren the whole shall go to tne husband or widow, and if there is no
husband or widow to his heirs, according to the law regulating distribu-
tion of intestate personal estate Res. stat. Conn., 1866, p. 202, chap. 7,
sec. 544. The statute of thisstate also provides that an action for the death
ofa p*rson shall survive. Id., p. 22,sec.98. See gen. statute of Conn.,
1875, p. 422, sec. 9.
‘ Rhode Island: If the life of any person being a passenger fn any
stage coach or other conveyances, when used by common carriers, or the
life of any person whether a passenger or not in the care of proprietors
of or common carriers by means of railroad or steamboats, or the life of
any person crossing upon a public highway with reasonable care, shall
be lost by reason of the negligence or carelessness of such common car-
rier, proprietor of proprietors, or by the unfitness or negligence or agents
in this State, such common carriers, proprietor or proprietors shall be
liable to damages for the injury caused by the loss of life by such person
to be recovered by action or the case for the benefit of the husband or
| |
‘INJURY RESULTING IN DEATH. 219
foundation of an action and criterion of damages if death had
not ensued, and the injured party had brought the action.
But the claim of the administrator, and through him’ the next
of kin, is altogether different."
x
255. The Damages that the Plaintiff may Recover. The plain-
tiff’s recovery will be restricted to an amount sufficient to
widow and next of kin of the deceased person. One moiety thereof to
go to the husband or widow and the other to the children of the de-
ceased. Gen. statute of R. I., 1875, p. 444, chap. 176, sec. 16.
Texas: If the life of any person is, by reason of the negligence or
carlessness of the proprietor, own:r, charterer or hirer of any railroad,
steamboat, stage coach, or other vehicle for the conveyance of goods or
passengers, or by the unfitness, gross negligence or careless ness of their
servants or agents, and whensoever the death of a person may be caused
by a wrongful act, negligence, unskillfulness or defanlt, and the act, ne-
glect, unskillfulness or default is such as would, if death had not en-
sued, have entitled the party injured to maintain an action for zuch in-
jury, then, and in any such case, the person who would have been lia-
ble if death had not ensued, shail be liable to an action for damages,
notwithstandihg the death of the person injured, and although the death
shall have been caused under such circumstances as amsunt in law to a
felony. Paschal’s dig , 1866, p. 98, art. 15, sec.1. Every such action
shall be for the sole and exclusive benefit of the surviving husband
wife, child or children and parents of the person whose death shall have
been so caused, and may be brought by such entitled parties or any of
them, and, if said parties fail for three calendar months to institute suit,
then it shall be the duty of the executor or administrator of the de-
ceased, unless specially requested by all of said parties entitled not to
prosecute the same In every such action the jury may give such
damages as they may think proportioned to the injury resulting from
such death, and the amount so recovered shall be divided among the
person or persons entitled to this act, or such of them as’ shall then be
alive, in such shares as the jury shall find and direct, and shall not be
liable for the debts of the deceased. Id, Sect 1.
7 Quinn v. Moore, 15 N. Y. 435; Ohio, &c ; R. R. Co. v. Lindell, 13 Ind.
366; Telfer v. North R. Co., 3N. J. L. 188.
220 LAW OF DAMAGES,
compensate the persons for whose benefit the suit is brought
for the loss, in a pecuniary sense, that they have sustained by
reason of the death of the injured person, or, in other words,
that nothing can be allowed for in damages which is not of a
definite pecuniary value.’
The suffering of the deceased person from the injury and
the grief and distress of his relatives are never considered in
estimating the damages. “These statutes seem to have been
enacted upon the idea that as a general fact the personal assets
of the deceased would take the direction given them by law,
and hence the amount recovered is to be distributed to the
wife and next of kin in the proportion provided for in the dis-
tribution of personal property left by a person dying intestate.
If the person injured had survived and recovered he would
have added so much to his personal estate which the law on
his death, if intestate, would have passed to his wife and next
of kin; in case of his death by injury the equivalent is given
by asuit in the name of his representative.”* Hence, there
' Safford v. Drew, 3 Duer. 627; Lehman v. Brooklyn, 29 Barb. 234; Tel-
fer v. Northern R. R. Co., 30 N J. 188; Chicago vy. Major, 18 Ill. 349;
Chicago, &c., B. Co. v. Morris, 26 Ill. 400; Pa. R. R. Co. v. Henderson, 51
Pa. st. 315; Rredes v. Smith, 66 N. C. 154; Pa. R. Co. v. Keller, 67 Pa. st.
300; Shearman & Redfield on Neg , 701; Duckwood v. Johnson, 4 H. &
N. 653; 8. C. 7 Law Reg. 630: Franklin v. S. E. R. Co., 3 H. & N.* 211;
Blake v. Mid. R. Co., 18 B. 93; S. C. 83, English com. law and eq. 93; 10
Eng. law and eq. 437; Gilard v. Lan & Y. R. Co., 12 L. T. 356; Pa. R. Co.
v. McCloskey, 23 Pa. st. 526; Whitford vy. PanaR. Co., 23 N. Y. 465;
Canning v. Williamstown, 1 Cush. 451; North Pa. R. Co. v. Robinson, 44
Pa. st 175; State of Md., &., v. the B. & O. R. Co., 24 Md. 84; S. C.5
Am. Law Redgs. (N. 8.) 397; Cleveland, &c., R. Co. v. Rowan, 66 Pa. st.
393; II. Cent. R. Co. v. Baches, 55 Il. 379; TL. Cent. R. Co. v. Weldon,
52 Ill. 290; Pa. R Co. v. Zebe, 33 Pa. st. 318; Pa. R. Co. v. Kelly, 3 Pa. st,
372; Pa. R. Co. v. Vendever, 36 Pa. st. 298; Mclntyre v. N. Y. Cent. B
Co , 47 Barb. 515; Donaldson v. Miss & Mo. R. Co., 18 Id. 280; Conant v.
Griffin, 48 Ill. 410; Field on the law of damages, sect 630; Long v. Mor-
rison, 14 Ind. 595; O. & M. R. Co. v. Tindal, 13 Ind. 366.
8 R, R. Co. v. Barron, 5 Wall 90; 1 Bessell, 543,
INJURY RESULTING IN DEATH. 221
can be no recovery for the loss of the society of deceased, ex-
cept so far as implies the loss of valuable service. And, where
any claim is made for the loss of training or education, the
capacity of the deceased as an instructor must be shown. Ex-
emplary damages are never allowed in this class of cases un-
less they are expressly provided for by statute.’ The plaintift
may recover for the pecuniary value of the life of the deceased
to those interested therein as provided by the statute and such
as arise from the loss of personal care and training and intel-
lectual and moral culture which would have been received by
the parties had the deceased lived. The rule is that the al-
lowance for injuries embraces whatever may be a source of
pecuniary injury to the widow and next of kin, and the jury
is allowed great latitude in estimating the damages.’ Courts
have experienced great difficulty in getting at the pecuniary
loss with precision or accuracy, and the question must be left
in almost every case to the sound sense and deliberate judg.
ment of the jury.t
256. The Pecuniary Damages that may be Recovered Must be
Definite. The pecuniary damages that can be recovered in
most of the States for the death of any person must be some-
thing definite and almost of a commercial value, but there may
be a recovery, however, without showing that the deceased.
was under any legal obligation to the next of kin. If the
5 It has been intimated in some cases that even in the absence “of
statutory provision that exemplary damages might be allowed. Shear-
man v. West. Stage Co., 24 Iowa 516.
6 McIntyre v. N. Y. Cent. R. Co., 37 N. Y. 287; How. Pract. 36, 15 N.
Y. 435; Field on the law of dam., sect. 631; Tilley, adm., v. the Hudson
River R. R. Co., 29 N. Y. 253.
7 Pa, R. Co. v. Keller, 67 Pa. st. 300; Tilly v. Hudson River R. R. Co,
supra; Duckworth, adm., v. Johnson, 4H. & N. 653; Palmer v. Erie R.
R. Co., 34. N. J. L. (5 Broom) 151.
1 Railroad Co. v. Barron, 5 Wall 90.
222 LAW OF DAMAGES.
plaintiff can show that they had a reasonable expectation of
pecuniary advantage from the continuance of the life of the
deceased, it will be sufficient. Thus, if he was in the habit of
bestowing gifts and presents upon them at regular intervals,
this would lay the foundation for damages.’
e
Much more are damages recoverable where the deceased
was legally bound to take care or render service to the next of
kin,? as in case of a minor child whose service belong to the
parent.’
. 257. The Expectations are to be Considered. As has already
been said,the legal liability alone isnot the test of injury in re-
1Tn an action by the father to recover damages for the death of his
son, it appeared that the son, who earned good wages, had been in the
habit for several years of contributing to the support of his parents, who
were in humble circumstances, by making them frequent and small
presents of groceries and by becoming responsible for their supply of
meat. Held, that damage might be given to the plaintiff in respect of
his being disappointed in a reasonable expectation of pecuniary advan-
tage by the continuance of his son’s life. Dalronv. 8. E.R. R. Co., 4C.
B. (N. 8.) 296.
* The charge of the Judge was explicit that the damages must be lim-
ited to the pecuniary injury, and he said that in estimating them they
had a right to consider the loss (that is the pecuniary loss) which the
children had sustained in reference to their mother’s nurture and in-
strnction and moral, physical and intellectual training. I think that
this does not imply that the children are necessarily and inevitably sub-
ject to such loss, but leaves it to the jury to determine whether any such
loss has been, in fact, sustained, and if so the amount of such loss. This
is the fair scope and meaning of the charge, and if it was not sufficiently
explicit should have been made so by direct request for such purpose.
This understood, I regard as unexceptionable. It is certainly possible,
and not only so, but highly probable, that a mother’s nurture, instruction
and training, if judiciously administered, will operate favorably upon
the wordly prospects and pecuniary interest of the child. The object of
such training and education is not simply to prepare them for another
world, but to act well their part in this and to promote the temporary
welfare. Tilly, adm., v. the Hudson River R. R. Co., 29 N. Y. 252.
* Quinn v. Moore, 15 N. Y. 432; Oldfield v. Harlem R. Co.,14.N, Y. 310
INJURY RESULTING IN DEATH. 223
spect of which damages may be recovered under these statutes,
but the reasonable expectation of pecuniary advantage by the
surviving relatives is sufficient to authorize a recovery. The
plaintiff or injured party, in order to recover must show some
ground on which his expectations are founded. The law has
not limited the evidence that may be introduced upon this
point to any definite channel, but leaves the parties free to
select from the circumstances and facts such as are calculated
to lead to such conclusion. The jury will not be permitted to
makea mere guess in the matter.
258. The Presumption. In case of an action brought un-
der these statutes for the benefit of the widow and minor chil-
-dren, after the relation that the deceased sustained to the
claimants has been established, the law will presume that
they have been injured.? And also in case of a suit for the
death of a child for the benefit of a parent.’
255. The Situation of the parties. It is now settled beyond
controversy that the damages that may be recovered in a case
1 Dalton v. Southeastern R. R. Co.,4C. B. N. 3, 296; Franklin v. §. E,
R. R. Co., 3 H. & N., 211; Condon v. G. &. R. R. Co., 16 Ir. C. L.R.,
415; 10Ir. Jur. N.S, 194. Railroad Co. v. Barron, 5 Wall., 90; Keller v.
N.Y. &. R. R. Co., 27 How. Pr., 102; Paulmin v. Erie R. R. Co., 34 N.
J., 151; Pa. R. R. Co. v Keller, 67 Pa st., 300; Oldfield v.N Y. &., 14
N. Y., 310; McIntyre v. N. Y. &c., R. Co, 37 N. Y., 287; Grotenkemper
v. Harris, 25 Ohio st., 870. It has been held that in most instances there
must be evidence of pecuniary loss on the part of the survivor, for
whose benefit suit is brought. Chicago R. R. Co. v. Morris, 26 T1l., 400-
403; Dickens v. N. Y. etc. R. R. Co., 1 Able Dec. 504.
? Dunhene vy. Ohio Life &c. Co., 1 Disng. 257.
8 Chicago v. Scholten, 75 Ill., 468; Condov.G.S R. R. Co., 16 Ir. C. L.
R., 415; Baltimore R. Co. v. Kelly, 24 Md., 271. But see Bell v. Wooten,
53 Ga., 648; Allen v. Atlanta Street R. Co., 54 Ga, 503; Ibl v. Forty-
-Second Street, &c. k. Co, 47 N. Y., 317. And it would seem that wher-
ever it is established that the deceased was under legal obligation to
support the claimants, that the court or jury trying the cause will pre-
sume damages. .
224 LAW OF DAMAGES.
of thie nature are, by the statute, to be assessed with refer-
ence to the pecuniary injury resulting from such death, to the
wife, children, or next of kin of such deceased person. They
are never assessed on the wants or needs of the claimants, or
on any moral obligation which may have rested upon the de-
ceased to supply their wants. Asa rule what the claimants
would lose by the death would be what they were accustomed
to receive, or had reasonable expectation of receiving in the
lifetime of the deceased. And to show that the claimants
were poor has no tendency towards showing that this was, or
was likely to be large or small. But we think there are cases
where such proof would be admissable for the purpose of show-
ing a moral obligation to demand assistance in the future from
one at the time incapable of’.giving it, as when the person
killed was a mere young child, and at the time contributed
nothing in aid of any one
260. Limitation. In many of the States the amount of re-
covery is limited. There is no such limitation, however, in
Lord Campbell’s act. But with the exception of two or three
States where exemplary damages are allowed the recovery is
limited to the pecuniary injury sustained by the claimants by
reason of the death of the deceased. The damages may include
the pecuniary value of the life of the deceased to the claimants,
and such as arise from personal care and training and intellec-
* Chicago R. R. Co. v. Bayfield, 37 Mich., 205; Ewen v. The Chicago R.
R. Co., 38 Wis., 613; Baily v. Railroad Co., 4 Bliss, 430; Chicago v. Pow-
ers, 42 Ill, 169. Butit isa sort of evidence that when necessarily re-
ceived ahouta be handled with great caution. Potter v. Chicago R. R.
Co., 21 Wis., 372; Penn. R R. Co v. Zelee, 33 Pa. st., 318; Belknap v.
Boston ete. R. R., 49 N. H 358; Hunt v. Chicago R. R. Co., 26 Iowa; Gu-
engerrech v. Smith, 34 Ia., 358; Karney v. Paisly, 13 Ia, 89; Condon v.
G.S ete. Co., Ir. C. L. R., 415. It was held in one case that if the fam-
ily was poor, the fact that the boy would probably have early begun to
assist in supporting his parents might be considered by the jury; Baily
v. Chicago R. Co., 4 Biss,, 430.
INJURY RESULTING IN DEATH. 225
tual and moral culture which would have been received by
the surviving relatives had the deceased lived.®
261. What the Plaintiff may Show to Enhance Damages. The
plaintiff may show for the purpose of enhancing his damages
the pecuniary situation, the annual earnings, habits and
health of the deceased, the profits of his labors and business, -
what he would probably have earned for the support of those
for whose benefit the suit is brought, the reasonable expecta-
tion of life of the deceased at the time he received the injury,
and for this purpose he may refer to the “Carlisle,” “or other
tables of recognized scientific accuracy relating to expectation
of human life.”
262.. Damages that may be Recovered by Children for Loss of
Parents. The rule is that damages are to be assessed with ref-
erence to the pecuniary injury sustained by the next of kin on
account of the death, and the jury are not confined to the
actual present loss which the party has sustained, but they
should consider prospective losses, provided the prospective
loss is such as they believe, from the evidence, will actually re-
sult to the next of kin or claimant as the proximate damages
arising from the wrongful death. Thus, it was held that the
‘Injury to the children by the death of the mother is a legiti-
mate ground of damages, and that in estimating such damages
the jury had theiright to consider the loss of the children of
the deceased in reference to such intellectual, moral and phy-
sical training and such instruction as they would otherwise
have received at her hands; that they should consider the bus-
® McIntyre v. N. Y Cent. R. B., 37 N. Y. 287; 35 How Pract. 36; Field
on the law of damages, sect. 631.
5 Rawley v. London, &c, R. Co., 8 Ex. 221; 41 L. J. R. N.S Exch. 153,
David v. 8S. W., R. Co., 41 Ga. 223; Danaldson v the Mississippi, &c, R.
Co., 18 Ia. 280; Field on the law of damages, sec, 632.
226 LAW OF DAMAGES.
iness and other capabilities of the mother in reference to her
competency to discharge her duty towards the pecuniary ben-
efit of the children in her intellectual, moral and physical
training of the children.®
263. How to Estimate the Damages. The rule in this class
of cases is not an exception to the general rule in all cases of
‘tort, that the claimants shall be allowed such a sum as will
fully compensate them for the pecuniary loss they have sus-
tained. And where the suit is brought for the benefit of the
widow and children, the jury should allow such sum as would
be equal to the probable earnings of the deceased, taking into
consideration the age, business capacity, experience and habits
and health, energy and preseverance of the deceased during his
probable lifetime, if he had not’been killed. By adding these
to the value of ‘his services in the superintendence, attention
to and care of his family and the education of his children, of
which they have been deprived by his death.*’
268. ~ Elements of Damages. 1. The health of the deceased.
2. His business calling or profession.
3. His age.
5 Tilly, adm., v. the Hudson River R. R. Co., 29 N, Y. 252; Kansas Pa-
cific R. R. Co. v. Cutter, 19 Kansas 83; Huntington R. R. Co. v. Decker,
84 Pa. st. 419; March v. Walker, 48 Tex. 372.
Damages recoverable by the wife for causing the death of the husband
may be estimated with reference to the fact that it is the duty of the
husband to provide the wife with present support as well as maintain-
ance for the future, and she is entitled to such sum as, in a pecuniary
point of view, would make her whole. Rafferty v. Buckman, 46 Iowa
195; see Rockford, &c., R. R. Co. v. Delany, 82 Ill. 198; Chicago v. Hes-
ing, 83 II. 204.
® Baltimore, &c., R. R. Co. v. Wrightman, 29 Gratt 431; 8. P. Matthews
v. Warner, Id. 570; Chicago, &c., R. R. Co. v. Bayfield, 37 Mich. 205; 7
Cent. Law Journal 421..
INJURY RESULTING IN DEATH. 227
4. His business capacity.
5. His habits.
6, The profits of his labor, profession or business.
7. The probability for reasonable expectation of the life of
the deceased at the time of the injury.
‘
8. His energy and inclination to pursue his business. And
where the suit is-brought for the death of a parent, the jury,
in addition to these, should consider the loss that the children
have sustained, the nurture, education and physical, moral
and intellectual training which they would have received
from the deceased parent.’
264. Death of a Child. Where an action is brought for an
injury resulting in the death of a minor child, “the parents
may recover the pecuniary value of the child’s services during
his minority, together with the expense of care and attention,
etc., during his life.”! So, under Lord Campbell’s act, in an
action by a father for the death of his son, it appeared on the
trial that the father was old and infirm and the son young and
™ Telly v.the Hudson River R. Co., 28 N. Y. 252, 24 N. Y. 477; Duck-
worth v. Johnson, 4 N. & N.653; Rawleyv. London, &c., R. Co., 8 Ex. 221,
42 L. J. R. (N. 8.) Exch. 153; David v.S W.R. BR. Co., 41 Ga. 223; Don-
aldson v. the Mississippi, &c., R. Co., 18 Ia. 280; Blake v. Midland R. Co.,
supra.; Field on the law of damages, sect. 632; Baltimore, &c., R. R. Co.
vy. Wightman, 29 Gratt 431;S P. Matthews v. Warner, Id. 570; Chicago,
&e., R. R. Co. v. Bayfield, 37 Mich. 207; 7 Cent. Law Journal 421; 3 Law
Journal 1880, page 48.
» Penn. R. Co. v. Zebe, 33 Pa. st. 318; Condon v. the G. 8. W. R. Co.
16 Irish L. R. (N. S.) 415; Peck v. May of N. Y., 3 Court 489; Potter v
the Chicago R. Co., 21 Wis. 372; Rockford, &c, R. R. Co. v. Delany, 82
TIL. 198; Chicago v. Hesing, 83 Ill, 204; Field on the law of dam., sect.
640. : ;
228 LAW OF DAMAGES.
earning good wages, and had assisted the father, and that the
father had a reasonable expectation of pecuniary benefit from
the continuance of the son’s life, the court held that the action
could be maintained.”
The parents’ recovery of prospective damages will be lim-
ited as a rule to the period of minority.’
265. Actions by the Parents. Quite a number of the States
have statutes authorizing parents to sue in their individual
names for the death of their child or children. But the nature
of the action is so near alike the one we have been considering
in the preceding sections that the rule for the assessment of
‘damages is the same. The statutes that authorize the execu-
tor or administrator to sue, only makes him a nominal party,
and he has no interest in the claim whatever.’
266. In Pari Delicto. In. the case of Martin v. Wallace,
the Supreme Court of Georgia held that since the gstablish-
ment of the national authority in that State that no action
could be maintained by a widow against a Railroad Company
for negligently, causing the death of her husband where the
casualty occurred while the company was transporting the de-
ceased as an officer in the Confederate service for hire and was
2 Franklin, adm., v. the S. E. RB. Co., 3H. & N. 211; Dalton v. 8. E. R.
Co., 4 C. B. (N. 8.) 296, 27 L. J. R. C. P. 227; 3 Cent. Law Journal 1880,
page 48; Quinn v. Moore, 15 N. Y. 482; 0. & M. R. Co. v. Tendal, 13 Ind-
366; Shaw v. Boston, &c., R. Co., 8 Gray 45.
3 Ford v. Monroe, 20 Wend. 210; State of Maryland v. Baltimore, &c.,
R. R. Co., 24 Md, 84; 5 Am. Law Register 397; Tilly v. Hudson River R.
R. Co., 29 N. Y. 252; Connant v. Griffin, 48 Ill. 410; Pa R. R Co. v. Zebe.
33 Pa. st. 318; Condon v. G. 8. W. R. Co., 16 Irish L. R. 415; Peck v. R: R+
Co., 21. Wis. 372. :
* Field on the law of damages, sect. 649; opinion of Cole in Sherman Vv.
West. Stage Co., 24 Ia. 550; 8 Jur. N. 8. 819; 31 L. Q. B. 249, 10 W. R. 737,
6L.J.R.N.S8. 759.
INJURY RESULTING IN DEATH. 229
paid by the Confederate government, on the ground that the
employes of the company and the decedent were, while en-
gaged in such transportation, in in part delictor.*
267. Contributory Negligence. The rule that the plaintiff
cannot recover in case of contributory negligence applies in an
action for injury jn causing death, and there can be no re-
covery where the deceased immediately contributed to the in-
jury that caused his death. Nor can there be a recovery
where the death occurred from the negligent conduct of a fel-
low servant engaged in the same employment.*
* 40 Ga. 52.
5 Willett v. Buffalo, &c, R. R. Co., 14 Barb. 585; Penn, &c., Co. v.
Ogier, 35 Pa. st. 60; North Pa. R. R. Co. v. Robinson, 44 Pa. st. 175.
-6 Hutchison v. York R. R., 5 Exch. 348; Wigmore v. Joy, Id. 354; see
post chap. master and servant. ;
CHAPTER XIV.
LIBEL AND SLANDER.
Liset DEFINED. SLANDER DEFINED. Matice. THE GEN-
ERAL DAMAGES. SPECIAL DAMAGES. THE LOSS OF A HUS-
BAND MAY BE AVERRED AND PROVED. AGGRAVATED AND EX-
EMPLARY DAMAGES. FULL DEFENSE. PARTIAL DEFENSE,
MITIGATING CIRCUMSTANCES.
268. Inbel and Slander Defined. The word libel has been
defined to be any publication charging another with infamy,
crime, or of anything that tends to degrade, disgrace or injure
the character of a person, or bring him into contempt, ha-
tred or ridicule.’
The word slander has been defined to be “the utterance of
false, malicious and defamatory words, tending to the damage
and derogation of another.? “Slander and libel have this in
} Johnson v. Stebbens, 5 Ind., 364; Dexter v. Spear, 4 Mason, 115;
Commonwealth v. Clapp, 4 Mass., 163-168; Steel v. Southwick, 9 John-
son, 14; White v. Nichols, 3 How. U. 8. 266; Armstrong v. Moronda, 8
Blackford, 426; DeArmond y. Armstrong, 37 Ind., 35.
*3 Blackstone’s com. 123-125;
LIBEL AND SLANDER. 231
common, that each may be, and usually is, effected by means
of language.” The only distinguishing feature of difference is
that the one is effected by oral, and the other by written lan-
guage.®
269. Malice. Malice is essential to the maintenance of a
suit for either libel or slander, and means in its common ac-°
ceptation, il will toward some person, but in its legal sense it
is defined to be a wrongful act, done intentionally, without le-
gal justification or excuse. In ordinary actions for libel or
slander, malice in law is sufficient to authorize a recovery, and
it is to be inferred from the publication of libelous or slanderous
matter. The law only examines into the intention of the au-
thor of the mischief when it becomes an element in the cause
that produces the injury. In most, perhaps in all, injuries
against the person or property of another, the actual intention of
the tort feasor is only considered, if at all, for the purpose of en-
hancing the damages. If one killsa horse belonging to another
the fact that he did it in a negligent manner or maliciously
would not increase or decrease the plaintiff’s injury, arising
from the loss of the use of the animal. But thelaw considers
that the bad spirit that actuates an individual in the perpe-
tration of an injury to the peson or property of his neighbor,
is an injury to that neighbor, and allows him damages for that
injury. Therefore, the law permits the plaintiff in an action
for libel or slander to show expressed malice in aggravation of
damages.*
3 Townsen on Slander and Libel, sec. 18, p. 26.
4Dunn vy. Hall, 1 Ind., 344; 2 Greenleaf evid. sec. 418; Starky on
Slander, p. 47; Bodwell v. Osgood, 3 Pickering, 379-383. Where the
truth of the words had been pleaded in justification, and the plaintiff
at the trial offered to accept the apology and nominal damages if the de-
-fendant would withdraw the justification, which the defendant refused,
but did not attempt to prove it. This conduct was held proper for a jury
with reference to the question of malice, as well as that of damages.
. Simpson v. Robinson, 18 Law J., 73.
932 LAW OF DAMAGES.
270. The General Damages. The amount of damages that
the plaintiff may recover in this class of cases depends to a
very great extent upon the reputation and the character of
the parties, the nature of the publication and the surrounding
circumstances. The plaintiff is entitled to full compensation
for all actual losses that he has sustained by reason of the pub-
lication.®
271. Elements of Damages. The jury should consider: 1.
Mental suffering. 2. Circumstances of indignity. 3. The
public disgrace and all other actual discomfitures. 4. They
should also consider the probable future, as well as the actual
past. 5. The expense to which the plaintiff has been put by
being compzlled to come into court to vindicate his character.®
272. Special Damages. The plaintiff may allege and prove
and recover any special damages sustained by reason of the
slander or libel complained of. Thus, it has been held that he
may, when properly alleged, recover for injury to his trade,
business, the loss of a marriage,’ the loss of a sale of his real
estate,’ loss of customers in his business or profession,’ for the
desertion of chapels or theaters, the loss of a situation, the loss
of companionship and hospitality of friends. In general, the
plaintiff is entitled to full compensation for every injury that
is the natural consequence of the publication of the language.
1 True v. Plumer, 36 Me.
* Hicks v. Foster, 13 Barb 663.
3 Sanderson y. Caldwell, 45 N. Y. 398.
*1 Hill on Torts, 408.
5 Field on the law of dam. | 549,
® Hill on Torts, 408; Field on dam., 549; Fry v. Bennett, 4 Duer. 247;
Swift v. Dickinson, 3 Conn. 285; Duford v. Abadi, 23 La. 280; Fuller v.
Fenner, 16 Barb 433; Terwelling, 17 N. Y. 54; Willion y. Gait, 17 N. Y.
442; 1 Hunt v Jones, Cros. Jac. 499..
° Fry v. Bennett, 4 Duer. 247; Swift v. Dickerson, 2 Conn. 285; Dufort,
LIBEL AND SLANDER. 233
273. The Case of Lynch v. Knight. In this case the plain-
tiff brought suit against the defendant for slanderous words,
imputing to her a want of chastity. She alleges in her com-
plaint, by way of special damages, that by reason of the slan-
derous words her husband had abandoned her and failed to
support and provide for her. The court was somewhat divided
upon the question whether. she could recover such damages or
not. The question, however, was not directly decided, as they
held that the words spoken were not slanderous and that the
plaintiff was not entitled to recover anything. But the ques-
tion was a new one and elicited remarks from several members
of thé court. Lord Campbell, Chancelor, in commenting upon
the question, said: “Had the words contained the charge of
adultery by the wife, which the defendant pretended to know
and which he asserted as a fact, I should have thought the al-
‘legation of special damages sufficient to support the action.
In that case, the husband believing the charges to be true,
would have been justified in separating from his wife, and this
separation would have been the natural and direct and proba-
ble consequence of the slander. Although not the necessary
consequence, it would not have arisen from any idiosyncracy
in this particular husband. Most husbands would have done
the same, and the effect might have been foreseen and might
be taken to have been intended by the defendant when he
293
spoke the words.
274. Aggravated and Exemplary Damages. The plaintiff may
show for the purpose of enhancing his damages the pecuniary
y. Abadi, 23 La, 280; Fuller v. Fenner, 16 Barb. 333, but see contra as to
mental distress; Terwilling v. Wands, 17 N. Y. 54; Willion v. Gait, 17 N.
Y. 442; Field on law of dam., 549; see Evans v. Harras, 338 Eng. L. & E.
347; Tilk v. Parson, 2 C. & P. 201.
8 Lynch v. Knight, 94 L. & E. 5777; 5 L. J. N. J. 291; Sedgewick’s
-leading cases on the measure of damages, 729.
234 LAW OF DAMAGES.
circumstances of the defendant and his position and influence
in society, the rank and condition in life of himself, that the
defendant has reiterated the language at different times and to
different persons and any effort which the defendant has
made to have him indicted.* And if he can satisfy the jury
by all facts and circumstances that the publication or speak-
ing of the words complained of was wanton and malicious, they
may give, in addition, exemplary damages.°
275. Full Defense. The defendant may defeat the action
by showing that he never published the language complained of.!
He may also defeat the action by showing that he, at the
time of the speaking of the-words, was acting in the capacity
of a legislator and spoke the words in the legislative chamber
in discharge of his official duty as a legislator; or, that he was,
at the time he spoke the words, in litigation in a court of jus-
tice, and that he believed that the utterance of the words were
+ Townson on slander and libel, sect. 387; Mayne on dam., 274; Guy v.
Gregory, 9 C. & P. 587; Armstrong v. Pierson, 8 Iowa 29; Shipman v.
Burrows, 1 Hall 399; Harcourt v. Harrison, 1 Hall 474; Cornwall v.
Richardson, 1 Ry. & M. 305; 1 C. & Y. 106; Severance v. Hilton, 4 Foster
147; McGee v. Sodusky, 5 J. J. Marshal 185; Inman v. Foster, 8 Wend.
602; Dame v. Kedny, 5 Foster 318; Petrie v. Rose, 5 Watts and Seg. 364;
Holly v. Burgess, 9 Ala. 728; Chubb v. Gill, 34 Penn. st, R. 114; Miles v.
Vanhorn, 17 Ind 245; Haun vy. Wilson, 28 Ind. 296,
5 Field on law of dam , sect. 649; Hosly v. Brooks, 20 Ill. 115.
" Pelier v. Mit, 50 Ill, 511; Lewis v. Chapman, 19 Barb. 250; Humphries
v. Parker, 52 Me. 502; Ptayhersen v. Shook, 41 Ill. 142; Bodwell v. Swan,
3 Peck 376; Alderman v. French, 1 Pick; Updegrover v. Zimmerman, 13
Penn. st. 619; Scott v. McKinnish, 15 Ala. 662; Rumsy v. Webb, 1C. &
M. 104; Elere v. Evans, Anthony N. P. 23; Burns v. Webb, 1 Tyler 17;
Samuels v. Bond, Little sel. can. 158; Treat v. Broning, 4 Conn. 408:
Bisby v. Shoen, 2 Kernan 67; Sheahan v. Collins, 20 111. 325; Haws vy.
Stapord, 4 Sneed 520; Sydgreaves v. Myatt, 22 Ala. 617 ; Golderman y.
Stearns, 7 Gray 181.
3 Townson on slander and libel, sect. 217,
LIBEL AND SLANDER. 235
necessary for the successful maintenance of his action or de-
fense, or that he was acting as counsel or attorney in conduct-
ing a suit and spoke the words while acting in that capacity.‘
An attorney has the privilege to speak anything that is perti-
nent to the matter in question between his client and the
opposite party,’ or he may defeat the action by showing that
he was, at the time of the publication of the words, acting as
the judge of a court of justice, and that in the discharge of his
official duty he uttered the offensive language;® or, he may de-
feat the action by showing that when he spoke the alleged
slanderous words he was a witness testifying in the trial of a
cause.” ‘
276. Partial Defense. The defendant may show in mitiga-
tion of damages:
1. That the plaintiffs general reputation is bad. The right
gf the defendant to attack the general character or reputation
of the plaintiff has been questioned and in some cases contra-
dicted, but he will only be permitted to introduce evidence to
attack that particular trait or quality to which the imputation
* Townson on slander and libel, 281.
5 Townson on slander and libel, 281.
® Townson on 8S. & L., Sect. 227; Goodman v. Topin, 1 Harm 60.
7 Garr v. Seldon, 4 Coms. 91; Weston v. Dobinet Cro. Joc. 482.
A witness is not bound to determine the materiality of the evidence,
and he may answer without liability for so doing questions put to him
’ and not objected to or not ruled out by the court. The fact that the tes-
timony is irrelevant or that the witness is influe:.ved by malice will not
render him liable for an action of slander. Calkins v. Sumner, 13 Wis
193; Barnes v. McCrete, 32 Maine 442; Grove v. Bundenburg, 7 Black
234; Wilson v. Noonan. 27 Wis. 598; Wright v. Schoeder, 2 Curtis 548;
McNutt v. Young, 8 Leigh 542; Young v. Bennett, 4 Scam. McCabe
y. Blanter, 6 Black 405; Saunders v. Johnson, 6 Black 50; Leonard v. Al-
len, 11 Cush. 241, 52 Ind. 442.
A femme sole brought an action of slander for words charging her with
fornication and adultery, Held, that the defendant might prove in miti-
gation of damages that the plaintiff’s character for chastity was bad.
Young v. McNutt, Leigh 542; McCabe and wife v. Platter, 6 Black 405.
236 LAW OF DAMAGES.
relates. ‘Thus, in an action of slander founded on the charge
of perjury, no evidence as to the character of the plaintiff can
be given in mitigation of damages, except for veracity.? And
he will be confined to the plaintiff's general reputation or char-
' acter and will not be permitted to prove particular instances
of bad conduct and corrupt acts entirely disconnected with the
offense charged in the libel or slander.®
2. He may show that he was provoked by the words or con-
duct of the plaintiff to utter the slanderous words.‘
3. He may show that the words were spoken in the heat of
passion or under excitement.®
4. He may show circumstances and conduct of the plaintiff
that led him to believe that the plaintiff was guilty of the
crime charged.‘
5. That he made the charges under mistake, which, on dis-
covery, he forthwith retracted.’
7. That the publication was communicated to him by are
spectable citizen.)
* Bell v Farnsworth, 11 Humph. 608; 1 Hill on Torts, 404. .
Where a woman sues for slanderous words spoken of her chastity, the
defendant may show that she has by her own dissolute conduct. destroyed
‘her reputation or character, and that, therefore, she is not damaged.
Field on the law of dam., 551. ;
* Field on dam., 551; Wilson v. Noonan, 27 Wis. 598; Fountain vy. West,
23 Ia 9; Fisher v. Tice, 23 Ia. 9.
* Freeman v. Tinsly, 50 Ill. 497; Miles v. Harrington, 8 Kans. 425; Moore:
v. Clay, 24 Ala. 235; McClintock v. Crick, 4 Ia. 453; Watts v. Frazer, 7
Ala. & Ell. 223.
® Mosler v. Harding, 33 Ind. 176.
* Shoult v. Muller, 1 Ind. 544; By. R. v. Monahan, 7 Black 83; Wasson
v. Canfield, 6 Black 406; Hayward vy. Foster, 16 Ohio 88; 1 Hill on Torts,
707; Field on dam., 552.
™Bradly v, Heath, 12 Pick. 163.
‘ Duncan y.. Daniels, 2 jur, 32; Maitland v. Goldrey, 2 East. 426.
LIBEL AND SLANDER. 237
8. “That he copies the same from another paper giving the
authority, or that he was demented or partially insane at the
time, or a monomaniac upon the subject matter of the charge.”
9. He may prove that when the words were spoken his
mind was so besotted by intemperance and his character so
depraved that no one who knew him would regard what he
said or give credence to any slanderous word he might have
uttered. .
? Field on law of dam., 552.
2 Gates v. Meredith, 7 Tud. 440.
When words have been uttered with malice and deliberate purpose,
or are merely low and idle expressions, the drunkness of the person ut-
tering them is proper to be considered. 7 Ind. 440; 3 Greenleaf evid., S.
6; Taylor’s Med. Jus. 656.
CHAPTER XV.
TROVER.
TrovER Drrinep As AN Act TO RecovER DAMAGES FoR RE-
TENTION OF PROPERTY. THE MEASURE OF DAMAGES. THE
PLAINTIFF WAIVES ALL DAMAGES FOR INJURY TO HIS PROPER-
ty. PRoFITS TO BE ALLOWED. THE CONFLICT OF AUTHORI-
TIES. THE RULE ALLOWING THE VALUE OF THE PROPERTY
AT THE TIME OF THE CONVEYANCE THE BEST. PROPERTY OF
PECULIAR VALUE. DAMAGES, HOW ESTIMATED. THE MARKET
VALUE NOT ALWAYS CONSIDERED. THE OLD RULE OF THE
COMMON LAW. EXEMPLARY DAMAGES AS A RULE NOT AL-
LOWED. GENERAL RULES.
277. An Action to Recover Damages for Retention. An action
of trover is a proceeding to recover damages against a person
who has had in his possession by any means personal property
of another, and has sold or used it without the consent of the:
owner, or who refused to deliver the same to the plaintiff
‘when demanded. The gist of the action les in the conver-
sion and deprivation of the plaintiff’s property.1. The plain-
tiff cannot recover unless he shows the right of immediate
11 Chitty’s Pleading, 135.
TROVER. 239
possession before or at the time of the conversion. The dif-
ference between trover and trespass is this, in trover the de-
fendant may have taken the goods by permission of the plain-
tiff, or in a lawful manner, as by finding, as has already been
said, the gist of the action is conversion. In trespass, the tak-
ing is always wrongful.’
278. The Measure of Damages. The measure of damages for
a conversion is generally the value of the property converted,
and interest at the legal rate per cent.‘
‘
278. The Plaintiff Waives all Damages for Violation of his Pos-
sessions. In this action, though the plaintiff’s possession has
been violated, he waives all claims to damages on account of
that violation, and seeks indemnity only for the loss of his
property. ‘ Hence it is that the value of the property at the
time of the conversion is prima facie the measure of damages
?1 Chitty’s Pleading, 149; Edmonson v. Nuttol, 17 C. B. N. S., 280.
® Cooper v. Chitty, 1 Burr,, 31 W. Bl, 67; Hill on Torts, 95 Field on
the law of dam., 3627.
4Kennedy v. Whitemill, 4 Pick., 466: Greenfield Bank v. Leavitte, 17
Pick. 1; 3 Camp, 477; Caster v. Feeland, 17 Mo., 150: Kennedy v. Strong,
14 Johnson, 128; Bucher v. Dennison, 13 Gray, 354; Dixon v. Caldwell,
15 Ohio st., 412; Sterling v. Garrett, 18-Md., 468; Rayborn v. Pryor, 14
Ark., 505; Ripley v. Davis, 15 Mich., 75; Yates v. Miller, 24 Ind , 277;
Polk v. Allen, 19 Mo., 467; Hurd v. Hubble, 26 Conn., 389; Cook v.
Loomis, 26 Conn., 483; Vaughn v. Webster, 5 Har., 256; Trall v. La-
thorpe, 30 Vt., 580; Culler v. Farring, 2 Vt. 580; Haden v. Bartlett, 35
Me., 203; Chase v. Monroe. 12 ; Heldborn v. Brown, 6 Texas, 45;
Carrier v. Minshall, 18 Cal.. 685; Parks v. Boston, 12 Pick., 198; An-
drews v. Durant, 18 N. Y., 496; McCommock v. Penn. Cent. R. R. Co.,
40 N. Y., 303; King v. Oesir, 4 Duer, 431; Robinson v. Hartridge, B.
Fla., 501; Dillenback v. Jerome, 7 Conn., 294; N. Y. Co. v. Silbeck, 52
Ill, 249; Pierce v. Berry, 14 Pick., 356; Ching v. Vial, 5 H. & N., 288;
Mayne on damages, 215; Read v. Fairhanks, I2 C. B., 692; Brisby v.
Kendall, 172 B., 937; Lamonda v. Daval, 9 id., 1030; Chambers v. Shaw,
18 Pick., 277; Johnson y. Stear, 15 C. B. N. 8., 330; Edmonson vy. Nuttal,
17 C. B. N.S. 280.
f
240 LAW OF DAMAGES.
But if the circumstances are such that the plaintiff can be in-.
demnified by asum of money less than the full value, there
seems to be no good reason why it should not be done, as where
the plaintiff has a special property, subject to which the de-
fendant is entitled to the goods. Suppose, for example, that
a factor has alien on goods to half their value. The principal
or owner of the goods becomes bankrupt, and the property
vests in his assignee, subject, of course, to alllegal liens. The
assignee, denying and intending to contest the factor’s lien,
gets possession of the goods and converts them. The factor
brings trover and recovers. .How shall damages be assessed?
To avoid circuity of action why should not damages be assessed
to the amount of his lien.’ A principle of law is that a man
cannot, by merely changing the form of his action, entitle him-
self to recover damages greater than the amount to which he
is in law entitled, according to the true facts in the case and
the real nature of the transaction.’ In the case of Bement v.
Lockwood, where the defendant took the plaintiff's horse and
wagon wrongfully and used them, the plaintiff, believing the
property had been stolen, went in pursuit of it and expended
considerable time and money in such pursuit. The plaintiff
brought suit to recover. The court held that he could recover
for his time and also for the money necessarily expended in
the use of reasonable means to repossess himself of the prop-
erty."
5 Chamberlain v. Shaw, 18 Pick 278.
Conner y. Val, 5 Hurl. & Noy. 288; Mayne on dam , 215.
Where one sells property to another on condition subsequent, and has
paid a part of the money by monthly installments, and the property is
taken from him, he may, in action of trover, recover the full value of
the same. Anger v. T. P. M. Co, 1 Gray 621.
720 Wend. 223; McDonald v. North, 47 Barb. 530.
If the property has been restored that fact is to go in mitigation of
damages, but if the restoration is obtained by the offer and payment of
a reasonable reward, this amount, with interest from the time of pay-.
ment, is to be deducted from the property restored. Greenfield Bank v.
Lennett, 17 Pick 1; 14 Pick 356.
TROVER. 241
279. Suydam v. Jenks. In this, Duer, J.. commenting at
considerable length on the question of damages in an action of
trover, said: “It may be shown that had the owner retained
possession he would have derived a larger profit from the use
of the property than the interest upon its value, or that he
had contracted to sell it to a solvent purchaser at an advance
upon the market price, -or that when wrongfully taken or con-
verted it was in course of transportation to a profitable market
where it would certainly have arrived, and in each of these
cases the difference between the market value, when the right
of action accrued, and the advance which the owner, had he
retained the possession would have realized, ought plainly to
be allowed as compensatory damages, and such is to be in-
cluded in the amount for which the judgment is rendered. So,
where it appears that the owner in all probability would have
retained possession of the property until the time of trial or
judgment, and if then of greater value than when he was dis-
possessed, the difference may fairly be considered a part of the
actual loss resulting to him from the change of possession, and
should, therefore, be added to the original value to complete
the indemnity. * * * Even when the market value of the
property, where the right of action accrued, would more than
suffice to indemnify, it is not in all cases that the liability
should be limited to that amount. It is for the value that the
defendant has himself realized or might realize that he is
bound to account, which judgment should be rendered
against him. Hence, should it appear in evidence upon the
trial that he had in fact obtained on the sale of the property a
larger price than its value when he acquired possession,
or that he still retains possession, and that an advanced price
could then be obtained, in each case the increase upon the
original value (which would otherwise remain a profit in his
hands) ought to be allowed as cumulative damages. * * *
‘It seems to us exceedingly clear that the highest price for
which the property could have been sold at any time after the
\
242 LAW OF DAMAGES.
right of action accrued and before the entry of the judgment,
cannot, except in special cases, be justly considered as the
measure of damages. When the evidence justifies the conclu-
sion that the highest price would have been obtained by the
owner had he kept possession, or has been obtained by the
wrong-doer, we have admitted and showed that it ought to be
included in the estimate of damages in the first case as a por-
tion of the indemnity to which the owner is entitled, and in
the seeond as a profit which the wrong-doer cannot be per-
mitted to retain, but we cannot admit that the same rule is to
be followed where nothing more is shown than a bare possi-
bility that the highest price would have been realized, and
still less where it is shown that it would not have been ob-
tained by the owner and has not been obtained by the wrong-
doer.”
280. The Conflict of Authorities Ought to be Reconciled. From’
all the authorities that it has been our pleasure to examine we
find that different rules prevail in different States for assessing
damages in actions to recover personal property or the value
thereof in case of conversion. It does seem that this want of a
uniform rule should not exist, and that a rule should be estab-
lished which would be applicable to all cases of this kind.
This could be done without difficulty by saying that the in-
jured party, in all cases where personal property is wrongfully
taken or unlawfully detained, whether by force or fraud or
process of law, shall recover the property and damages for its
13 Sandf. 614; see also Cheney v. Wall; 5 Hurl. & Nov. 288, The
above case has been overruled by Baker v. Drake, 53 N. Y. 211.
When the defendant, who was employed by the plaintiff to dig a
canal, converted the dirt to his own use, the court held that the measure
of damages was not what the clay was worth over and above the value of
the labor of excavating, but what it was worth to the defendants who
appropriated it to their own gain and profit. Chicago & Dock Co. v.
Dunlap, 32 Ill, 207.
TROVER. 243
use and all necessary expenses incurred in trying to regain
possession or when the recovery of the property cannot be had,
then its value with damage, interest and expense.
Such a rule would have a strong tendency to break down
the technical forms of actions as they exist at common law,
simplify the practice and lessen the labor of the courts. Some
of the States have adopted a rule for the assessment of damages
in this class of cases that authorizes the plaintiff to recover the
highest market value of the property at any time between the
conversion and the time of the trial.’
281. The Supreme Court of Indiana. The Supreme Court of
Indiana, commenting in a recent case upon this question,
says: “The time of conversion is not, it seems, always fixed
. . by the same circumstances. Thus, a tortious taking is suffi-
cient proof of a conversion, but yet it appears from many of
the cases that the plaintiff may elect to consider the property
as still his own, and ‘treat a sale of it by the wrong-doer or a
refusal to deliver on demand as a conversion, or it has been
held that the law will, upon the principle of natural justice
that a wrong-doer ought not to be allowed to make a profit by
his own willful tort, treat the conversion of the property of
fluctuating value as occurring at such times between the tak-
ing and the trial, as’the property bears the highest price in
the market. The confusion in these cases seems in part to
have arisen out of the form of action. Some courts and judges
hold that by bringing trover the plaintift precludes himself
from showing that the taking was willful, and hence the in-
jury concerning damages must, in that form of action, be con-
2 Suydam v. Jenks, 5 Sandf. 614.
5 Ellis v. Wise, 33 Ind, 127; Emart v. Kerr, 2 McMullen, 141; Jenkins
v. McConico, 26 Ala. 213. ,
244 LAW OF DAMAGES.
fined to the value of the property at the time of the conver-
sion, without reference to the manner of taking. * O* a
Some loose ideas in reference to the time of the conversion
have also tended to darken counsel as to the measure of dam-
ages in trover, where the general rule that the value of the
property at the time of conversion has been held to be a uni-
versal rule. A wrongful taking and a demand and refusal are
each held in trover to be not a conversion, but merely a suffic-
ient evidence of it. And yet nothing can be clearer than that
these things do not change the title to the property. It still
remains in the plaintiff, and may by action of replevin be re-
covered in specie so long as its identity is perceptible to the
senses. It may be so recovered, though its form has been
changed and its value greatly increased. * * * The sale of
the wheat was its actual conversion by the defendant, and its
value at that time, in the form in which he sold it, was the
measure of damages, if the plaintiff was content therewith,
though we think he was entitled to the highest price of the
property at any time between the taking and sale. * * *
It is held otherwise in Massachusetts, but the ruling is main-
tained to preserve consistency of decisions, and not because it
was the doctrine of the common law. We do not like the
Massachusetts rule, and if the question was res integro we
would not adopt it, for the reason that it is too tender of the
willful tort feasor.” *
282. The Law Aims at Compensation. But reading the dif-
ferent conflicting opinions the fact should not be overlooked
that the law in awarding damages aims at compensation.
Keeping this in view, we think that an amount sufficient to
indemnify the plaintiff for all losses he has sustained, which
* Ellis v. Wise, 33 Ind., 127; see also Green v. Wilkins, 1 C & P., 625;
Brown vy. Saxe, 7Conn., 95; Bettsv. Lee, 5 Johns, 348; Barker y. Wheeler,
8 Wend., 505; Salsbury v. McCoom, 3 N. Y., 379.
TROVER. 245
are the natural, reasonable and proximate result of the wrong-
ful act complained of, and which a proper degree of prudence
on the part of the complainant would not have averted, should
in all cases be the measures of damages for the conversion of
property.*
232. The Value of the Property atthe Time of the Conversion and
Interest. The rule allowing the value of the property at the
time of the conversion, with legal interest, should be generally
adopted, for the reason that in the large rule or the rule allow-
ing the highest value between the time of conversion, and the
trial is so uncertain, indefinite, and is a wide departure from
the principle of compensation of actual loss. In the adoption
of the large rule the fact must have been overlooked that in
most cases of this kind the defendants retain the property in
good faith and in the henest belief that they are the real own-
ers and lawfully entitled to the possession. They should not,
therefore, be treated as wrong-doers in the strictest sense of the
term. Besides, the large rule leaves the time when the damages
are to be assessed indefinite and uncertain. The basis upon
which this rule rests is that the title to the property still re-
mains in the plaintiff, and that if the defendant had not con-
verted the same and retained it from the plaintiff he would
have sold it at the highest market price. But the presump-
tion has no foundation to rest upon, from the fact that the
gaeat majority of men retain personal property but a short
length of time, andif the true owner is permitted to retain his
property, in the great majority of cases he will sell or consume
it within a year. Suppose, that a defendant through the
‘Baker v. Drake, 53 N. Y. 211; Davis v. Oswell, 7 Cor. & Payne, 804
Hurd v. Hubble, 26 Conn 389; Saunders v. Bouries, 52 Mo. 50; Bizee v.
Mayber, 21 Wend. 144; Farmers’ Bank v. McKee, 2 Pa. st. 318; McDon-
ald v. North, 47 Barb., 580; Foythe v. Wells, 41 Pa. st. 291 » Bennett v.
Lockwood, 20 Wend. 223.
246 LAW OF DAMAGES.
honest belief that a colt three months old is his property,
which, at that time, was worth only fifteen dollars. He takes
possession of it, feeds and cares for it until it grows up to be a
large horse, worth, at the age of three years, one hundred and
fifty dollars. At that age he becomes diseased, and in a short
time perfectly worthless. It is now discovered for the first
time that the colt belonged to his neighbor, who at once brings
an action in trover for the property. To allow the plaintiff
the full value of the horse at any time between the taking and
the time of the trial would give him judgment for one hun-
dred and fifty dollars, ten times the value of the colt at the
time of conversion. This would be such a hardship as no
court ought to tolerate.®
284. Property of a Peculiar Value, Damages Hard to Estimate.
The courts have always had difficulty in adopting a rule for
the assessment of damages in cases of the conversion of property
of a pecular value to the owner, such as gifts and articles of
virtu. In this class of cases the general rule has been re-
laxed, and the plaintiff will not be confined to the ordinary
market value of the chattel, but the jury should be left to
assess its value under all the circumstances of the cases.®
* Romain vy. Van Allen, 26 N, Y. 309; Field-on law of damages, 641.
In Pennsylvania, where the defendant in good faith and in the exer-
cise of what was supposed to be proper authority, cut timber on plaintiff's
land to the value of $25, which he converted into hooppoles worth $700,
that the title passed to the defendant, he having in good faith expended
his labor in making the change. Forsyth v. Wells, 41 Pa. st. 291; Kerr
v. Patterson, 41 Pa. st. 357; Moody v. Whitney, 38 Me. 174; Chipman v.
Hibbard, 6 Cal. 162; Whitbeck vy. N. Y. Cent. R. R. Co , 36 Barb. 644;
Cox. v. England, 65 Pa. st. 212; Young v. Loyd, Id. 199; Sturges v. Keith,
57 Ill. 451.
6 Suydam y. Jenks, supra.; Whitfield v. Whitfield, supra.; Field on
dam., 649, Sedgewick on dam., 474; Stickney v. Allen, 10 Gray 352;
Whitfield v. Whitself, 40 Miss 352, 44 Miss. 254. 41 Miss. 368.
When the property converted has a fixed value, the measure of dam-
S
TROVER. 247
285. Chief Justice Parson. A very learned commentator,
in discussing the question, says: “We think it quite clear,
however, that this pretium affectionis cannot be recovered, unless
in case where the conversion or appropriation by the defendant
was actually tortious, and in that case we snould be disposed
to hold that the defendant should be made to pay what he
,would have been obliged to give if he had bought the article,
or at least that the damages might be considerably enlarged
in such a case on the principle of exemplary damages.”?
286. The Market Value Not Always Considered. Judge Duer,
in the case of Suydam v. Jenks, says: In most cases the mar-
ket value of the property is the best criterion of its value to
the owner, but in some cases its value to the owner may
greatly exceed the sum that any purchaser would be willing
to pay. The value to the owner may be enhanced by personal
or family considerations asin case of family pictures, plates,
etc., and we do not doubt that the pretium affectionis, instead of
the market price, ought then to be considered by the jury or
court in estimating the value. In these cases, however, it is
evident that no fixed rule to govern the estimate of value can
be laid down, but it must of necessity be left to the sound dis-
cretion of a jury in the exercise of a reasonable sympathy with
the feelings of the owner.”
ages is that value with legal interest from the time of the conversion.
Where the value is fluctuating, the plaintiff may recover the highest
value at the time of the conversion, or at any time afterwards. Douglass
v. Kraft, 9 Cal. 562, 33 Cal. 117.
1 2 Parson on con., 196
The measure of damages for the conversion of plates for printing labels
or advertisements of great value to the owner, but of very trifling value
to others, is the value to the owners, and in estimating this the costs of
replacing the plates may be considered. Stickney v. Allen, 10 Gray
(Mass.) 352. ;
23 Sand. 621; see Whitfield v. Whitfield, 40 Miss. 353, 44 Miss. 254;
Bickell vy. Colton, 41 Miss. 368; Stickney v. Allen, 10 Gray 352. -
’
248 LAW OF DAMAGES.
269. The old Rule of the Common Law. The old rule of the
common law, established several hundred years ago, that made
but little or no discrimination in the assessment of damages in
this class of cases between those who acted wilfully, and those |
who acted through mistake, has gradually yielded to thé force
of Christian influence, and is being modified in harmony with
rules of ethics and the law of conscience. And it has been
held in several well-considered cases that where the defendant
acts in good faith he “should enjoy the enhanced value
and the plaintiff only recover the value of the orignal
material.”* In the case of Wetherell v. Green, the Supreme
Court of Michigan held that where the defendant, in the
exercise of what he supposed to be legal authority, had cut
down timber of the value of twenty-five dollars into hoops
worth seven hundred dollars, which he converted, that the
measure of damages was the price of the timber.“ So where
an action of trover was brought to recover the value of coal,
and it appeared that the defendant had dug the coal from the
plaintiff’s mines by mistake, the court held that the measure
of damages was the value of the coal before it was mined, and
such other damages to the land as the mining may have
caused.® And we think that this distinction should be ob-
served in all cases where the evidence shows that the defend-
ant actedin good faith in converting the property. The rea-
son for the establishment of the old rule was that to permit a
party to retain any part of goods which he had acquired
wrongfully would encourage vice and crime. The fact, how-
ever, was entirely overlooked that by the enforcement of the
rule innocent men were often made to suffer. But in order to
°2 Parsons on cont., 479; Field on dam., 653; Hyde v. Coopson, 21
Barb., 92.
422 Mich., 311; Foster v. Wells, 41 Pa. st., 291.
Forsyth v. Wells, supra; Keer v. Patterson, 41 Pa. st., 357; Moody v.
Whitney, 38 Me., 174; Chipman v. Hibbard, 6 Cal. , 162; Whitebeck v.
N. Y. Cent. R. R. Co., 36 Barb., 644; Cox v, England, 65 Pa. st. 212;
Young’ vy. Lloyd, 65 Id, 195.
TROVER. 249
-prevent fraud and crime, the courts should require the strict-
est proof that the defendant acted in good faith, and in the hon-
est belief that he had a right to convert the property to his
own use. This rule should be applied in the case of an inno-
cent confusion of goods.®
288. Should Exemplary Damages be Allowed? The gestion as
to whether exemplary damages may be allowed in an action of
trover is not well settled by the authorities. The old decisions
are against the allowing of such damages. But the recent
cases, where the question has been properly raised, have gen-
erally held the other way, and have failed to confine the jury
to the assessment of compensatory damages only,” From what
has been said we will proceed to lay down some general rules:
1. The plaintiff in an action of trover may recover the
value of his property at the time of the conversion, with legal
interest, and all expense incurred by him in the use of reasona-
ble means to repossess himself of his property.
2. To the above rule there is one exception, to-wit: When it
can be shown that had the plaintiff retained possession of the
property he would have derived a larger profit from the use of
it than the interest upon its value,or that he had contracted to
sell it to a solvent purchaser at an advance upon the market
6 Field on the law of dam., 654.
If the property has been restored that fact is to go in mitigation of
damages, but if the restoration is obtaind by the offer and payment of
a reasonable reasonable reward, this amount with interest from the time
of payment is to be deducted from the property restored. Greenfield
Bank v. Leavitt, 17 Peck. (Mass.) 1.
7 Dennis v. Barber, 6S. & R., 420; Nuber v. Kelley, 69 Penn. st., 403;
Backenstor’s v. Stahier, 33 Pa. st , 251; Baker v. Wheeler, 8 Wend., 505;
Whitehouse v. Atkinson, 3 C. & P., 344; Pribble v. Kent, 10 Ind , 325,
Jones v. Rohill, 16 Minn., 320.
250 LAW OF DAMAGES.
price, or that when wrongfully taken or converted it was in
course of transportation to a profitable market, which it would
certainly have reached. In each of these cases the difference
in the market value when the right of action occurred, and
the advance which the owner, had he retained possession would
have realized, should be allowed as damages in addition to its
value at the time of conversion.’
1 Suydam v. Jenkins, 3 Sandf., 641.
In a suit for conversion of a promissory note, in the absence of proof,
the presumption is that the instrument is worth the sum payable on it.
Menkins v. Mekins, 23 Mo.; 252; Bedo v. Mutual Saving Inst, 28 Mo.,
181; Ingalls v. Lord, 1 Cnm. N. Y., 240; Potter v. Merch. Bank, 28 N.
Y., 541; Seals v. Cummings, 8 Hump. (Tenn.) 442; Robbins v Packard,
31 Vt., 570.
’
CHAPTER XVI.
REPLEVIN.
AcTION oF REPLEVIN “UNDER STATUTES. WuHAT PRUPERTY
MAY BE REPLEVIED. EXCEPTION TO THE GENERAL RULE.
FIXTURE, HOW DETERMINED. INSTANCES IN ILLUSTRATION
*» OF THE RULE. THE MEASURE OF DAMAGES. DAMAGES WHEN
THE PROPERTY CANNOT BE RETURNED. RuLeE IN Kansas,
EXEMPLARY DAMAGES. THE PLAINTIFF’S INTEREST. THE
AMOUNT OF THE PLAINTIFF'S RECOVERY. DAMAGES IN CASES
WHERE THE PROPERTY IS NOTRETURNED. ARTICLES OF PECU-
LIAR VALUE. DEFENDANT’S DAMAGES IN CASE A JUDGMENT
OF RETURN IS RENDERED.
289. Action Under the Statutes. At common law trespass
was the proper form of an action for the recovery of special
damages for the wrongful taking of goods, and that in trover
for the value of the goods converted. But under the statutes
of most of the States the action of repleving is now generally
used for the recovery of specific personal property wrongfully
taken or detained and the damages for its detention. The ac-
tion under these statutes combines all the elements both of-re-
plevin and detenure at common law. The plaintiff can re-
252 LAW OF DAMAGES.
cover in this action his property and all damages that he has
sustained by being kept out of possession.’ And if for any
feason the property cannot be found or returned by the officer
holding the writ, he should let his return of the writ show
_ that fact; and, if the plaintiff can show the value of the prop-
erty on the trial, he can recover the value: thereof, together
with his damage for its detention. The statutes of several of
the States provides, in fact we believe the general rule is,where
the officer holding the writ has failed to return the property to
the plaintiff, the court will render a judgment in favor of the
plaintiff in the alternative that he recover the possession of the
property, or in case it is not being returned, then the value
thereof, together with the damages for its detention.’
290. What Property may be Recovered. A question not free
from, difficulty occasionally arises in this class of cases as to
what property can be recovered in this action. Law commen- ©
tators and courts have never been able to draw an accurate
line between real and personal property, and there is a want
of uniformity in the decision of the courts of the different
States upon the question” Land is always regarded as real
property, and ordinarily, whatever is erected or growing upon
it, as well as whatever is contained within it or beneath its
surface, as mineral and the like.®
291. The Exceptions to the General Rule. There has been ef-
fort after effort put forth by courts of this and other countries
to lay down some definite rule by which to distinguish real
‘ Mitchell v. Burch, 36 Ind., 529.
? Whitney et al. v. Lehmer et al. 26 Ind. 508; Ramly v. Gibbs, 15 John-
son, 385; Young v. Willet, 8 Bos. (N. Y.) 486; Frazier v. Frederick, 4
Zab. N. Y., 162; Gordon v; Jeny, 16 Mass., 455.
?Teaff v. Huett, 1 Am. Law Redg., 723.
* Washburn on real property, 32 Blackstone’s com., 17-19.
REPLEVIN. 253
from personal property, but so far they have only partially
succeeded, and the old vexed question as to what is or is not a
fixture now and then is presented to the courts for their con-
sideration and adjustment. It would be out of place for us to
even attempt to discuss the question in this work, and we will
only lay down a few rules that may assist the student to un-
derstand the subject: 1. A fixture is any article which was a
chattel, but by being physically annexed or affixed to the
realty becomes a part of it.’
292. The Rule for Determining What is a Fixture. In order
to determine whether an article is a fixture or not, inquiry ,
should be made as to whether it is attached to the realty in
such a manner as to preclude the idea of its removal by the
person who placed it there. In settling the question, the bus-
iness of the party who placed it on the land and the general
usage of the country in regard to the subject matter should be
considered. The intention of the party in making the annex-
such action. How is thearticle attached to the freehold? What
was the general practice and usage of the county in regard to
articlesat the time of the annexation? Ifthe answers to these
questions are not sufficient to afford any clear indication in
regard to the matter, then resort must be had to time and pur-
pose of the erection and the expectation and understanding of
the parties’ interest in opposite directions at the time the an-
nexation was made.‘
293. Instances in Illustration of the Rule. And it has been
held that between a vendor and purchaser growing crops
planted by the owner of the soil, constitutes a part of the realty.
o
a Teaff v. Huett, 1 Am. Law Kedg.. 723.
6 2 Redfield on wills, 158; Dudley v. Ward, Amb. 113; Harvey v. Har
vey, 2 Strange, 1141; Wood v. Gaymon, Amb. 395.
254 LAW OF DAMAGES.
But, if planted by a tenant who holds under the owner of the
soil, they will be regarded as personal property.’ The Supreme
‘Court of Indiana, in a recent case, held that a house built by
mistake upon the streets of a city was personal property, and
could be replevied.1 But where an article is made personal
property by being severed from the realty to which it first be-
longed, it may be replevied as long as its separate identity can
be ascertained whatever shape it may take, but when an ar-
ticle of personal property, though wrongfully taken, has be-
come real estate by being attached to the realty, it cannot be
replevied because it has lost its separate identity and its char-
acter as personal property. Therefore, if rails are wrongfully
taken from a fence, they become personal property, and may
be replevied by the owner; but, if after their wrongful taking
they are again attached to realty by the wrong-doer, they at
once become fixtures and cannot be' replevied by the owner.?
294. The Measure of Damages. The measure of damages, as
has already been said in an action of replevin, as a rule under
these statutory provisions, where the property has not been
delivered to the plaintiff, is the vaule of the property at the
time of taking or ‘the highest subsegent value at the time of
the bringing of the suit or the trial of the action, according as
the courts of the different States may hold upon the question.’
The damages for the detention are the same whether the plain-
tiff recover his property or not.’
71 Washburne on real property, 5.
1 Fay and others v. Reddick, 3! Ind. 414.
Ricketts v. Dorrell, 55 Ind. 470.
2 Dewitt v. Morris, 13 Wend. 496.
But in a recent case in New York it was held that the plaintiff could,
where the property could not be found, recover its value at the time of
the trial. Co .v. Flinn, 55 N. Y. 633. es ,
® Allen v. Fox, 51 N. Y. 562; the N. Y. G. Co. v. Flinn, 55 N. Y. 423;
Field on dam., 660.
The general question which we deem it necessary to examine is what
REPLEVIN. 255
~ 295. Damages where the Property Cannot be Returned. If, for
any reason the property cannot be returned to the plaintiff, he
will be entitled to a judgment for its value at the time of the
is the proper measure of damages? The rule for ascertaining the sum
which the injured party ought to recover in all cases where personal
property is wrongfully taken or detained, whether by force, by fraud or
by process of law. It is a question of wide extent and corresponding
interest, and we are not without hope that the observations which we
intend to make may have some tendency to redeem this branch of the
Jaw from its present state of confusion and uncertainty. Unless we are
greatly mistaken, there are certain indisputable” rules or, more correctly,
principles of natural justice, by the application of which the amount that
the injured party ought to recover may in all cases be readily and cer-
tainly determined Sctting aside the exceptionable cases in which ex-
emplary damages may be justly claimed’ and given, and confining our-
Selves to those in which the remedy sought is simply pecuniary, the
principles which, as it seems to us, are manifestly just and universal in
their application are that the owner to whom compensation is due must
be fully indemnified, and that the wrong-doer must not be permitted to
‘derive any benefit or advantage whatever from his wrongful act ‘It may
frequently happen that these principles when applied will coincide in
the result, but there are many cases in which it will be seen that the ap-
plication of both is necessary. An indemnity must always be given to
the injured party, but it is not in all cases the measure of damages which
the wrong-doer ought to pay. First, the injured party must be indem-
nified ; he must be placed in the same situation in which he would have
been had the wrong not have been committed, or had it been instantly
repaid by the payment of compensation then dle. As the actual loss to
the owner is the same, whatever may be the form of the action in which
its reparation is sought, the sum due to him for its compensation must
be the same, whether he is plaintiff in trespass or trover or the defendant
in replevin. There can be no variance in the amount of an indemnity,
and, if a criterion can be fixed, any departure from the standard which
is established must be capricious and arbitrary, and must involve more
or less of injustice to one or the other of the parties to the injury. Then
what are the rules? What is the process of computation by which the
just amount of the indemnity may be ascertained? We reply with some
confidence that it will be ascertained in all cases by adding to the value
-of the property, when the owner is dispossessed, the damages which he
‘is proved to have sustained from the loss of his possession. It is when
the property is wrongfully taken or detained that the right of action
occurs to the owner. He is then entitled to demand compensation for
his loss, and, if his demand is then complied with, it is plain that the
value of the property at that time, by which we mean its market value,
256 | LAW OF DAMAGES.
trial, and damages for its detention.* Or its value at any sub-
sequent time, according the different rules heretofore stated.
But if the officer seizes and returns the property to him, he
will be obliged to take it although it has been ey reduced
in value by the defendant or from any other cause.* But the
plaintiff will be entitled to recover damages for the difference
in the value of the property at the time of taking and its
value at the time of the trial, together with the value of its
use from the day he was deprived of it to the time of the trial.
But in most of the States, where the officer returns his writ
that the property has not been found, the plaintiff recovers
the value of the property at the time of the taking, or unlaw-
ful detention, with interest up to the time of the trial.”
296. The Rule in Kansas,'where the Property Cannot be Re-
turned. In Kansas, if the property cannot be returned, the
plaintiff can recover its value at the time of the wrongful
taking' and interest on that valu.2 An elementary writer
the sum for which it could then be sold, would constitute at least a por-
tion of the amount that the wrong-doer would be bound to pay. This
sum may, therefore, be fairly considered as a debt then due, and conse~
quently interest, until the time of trial or judgment, must in all cases be
added to complete the indemnity. Suydam v. Jenks, 3 Sandf. 641.
* Allen v. Fox, supra. The N. Y. G. Co. v. Flynn, 55 N Y , 423.
5 Allen v. Fox, supra; Field on law of damages, 660.
6 Allen v. Fox, supra; Clapp v. Walters, 2 Tex , 189; Darley v. Cara-
way, 2H. J., 413; Butler v. Mishering, 15 1]1., 488; Michel v. Burch, 36
Ind., 529; Tardy v. Howard, 12 Ind., 404; Chessom v. Lancool, 9 Ind.
530; Blacwkell v. Action, 38 Ind, 425.
™ Morgan v. Reynolds, 1 Mat, 163. Field on dam., 659; 3 Sand., 641;
McGarrock v. Chamberlain, 20 Ill., 219; Walls v. Johnson, 16 Ind., 374.
1 Garrett v. Wood, 3 Kansas. 231; Field on dam., 661; see also Tun-
nom y. Smart, 4 laws N. J., 262; Mayberry v. Cliff, 7 Cold (Tenn) 401.
? Barthol v.. Fox, 13 Minn., 501, Tunnom v Smartt, supra, Mayberry
v, Cliff, supra; Woodburn v, Cogdale, 30 Mo., 222; Hurd v. Gallagher, 14
Ta., 394; McNally v. Shobe, 22 Ia., 49; Motte v. Chicago &c. R. R. Co.,
2v Ja., 22; Conoway v. Flint. 5 Col., 327; Chicago R. Co. v. Shultz, 55
Ill., 421; Chapman v. Chicago R. Co., 26 Wis , 295; Suydam v. Jenkins,
3 Sand.. 614; Field on dam., 669.
REPLEVIN. 257
states the law thus: “When the property has been delivered
to the plaintiff and the jury find for him, they should assess
the damages for the detention, and he is entitled to compensa-
tion for deterioration in the value of the goods replevied,while
they were in the hands of the defendant, and also for his time
lost, and expenses incurred in searching for his property, and
to the hire of a slave. When the property has not been de-
livered to him the jury should also find the value of the prop-
erty. In this case the damages for the detention are usually
interest.’”
a
297. If no Proof of Damages is Made Nominal Damages are Al-
lowed. If the plaintiff makes no proof of damages, but shows
a wrongful taking or detention the court will allow nominal
damages.’ There are several authorities which hold that the
same principle should govern the damages, whether “the ac-
tion is in trover or replevin. In such case the value at the
time of taking, or the highest subsequent value to the time of
bringing the suit, or the trial of the action, according as the
courts may hold in case of trover. But there are many well-
grounded objections to this rule, and it is only adopted in a
few States.® .
? Morrison’s Replevin, 193-4; see also Bement v. Lockwood, 20 Wend.
224; Chitty’s R., 333; Saunders Pie. & Evid., 186; Mitchell v. Burch, 36
Ind., 529; Gordon v. Finney, 16 Mass., 470; Butler v. Silliman, 38 N. J.,
423.
_ If the plaintiff fails to recover the property, to show a wrongful tak-
ing the damages should be the same as in an action in trover. Field on
law of dam., 659.
® Phenix v. Clarke, 2 Gibbs, Mich., 327.
5 Field on law on law of dam., 661. Scott v. Rodgers, 31 N. Y., 588.
In an action for the recovery of personal property of a fluctuating
value, where exemplary damages are not allowed, the correct measure of
damages isthe highest market value within a reasonable time after the
property was taken, with interest from the time such value was esti-
tated. 39 Cal., 412.
258 LAW OF DAMAGES.
298. Exemplary Damages. There is some question in re-
gard to the right of the plaintiff to recover exemplary dam-
ages in an action of this character, but we can see no reason
why such damages should be allowed in case of trespass de bonis
asportatis, and not in one of this nature, for frequently
property is replevied from the hands of persons who have will-
fully taken it with intention of converting it to their own use.
Then if exemplary damages are allowed in an aggravated case
of trespass they should also be allowed the plaintiff in replev-
in under similar circumstances."
299 The Plaintiff’s Interest. In cases where the property
cannot be returned to the plaintiff, a question of some diffi-
culty may now and then arise in assessing the plaintiff's dam-
ages. If he is the owner of the property he is entitled toa
judgment for its value at a specified time. But suppose that
he is a mere bailee and has no interest in the property except
a temporary possession, he could then only recover his actual
damages. And if his interest is only a lien as by virtue of an
attachment, execution or mortgage, .to secure a debt, he can
only recover an amount sufficient to satisfy his debt.’
300. The Amount of the Plaintif’s Recovery in an Action of
this Character. The judgment for the plaintiff may be for the
delivery of the property or the value thereof, in case a delivery
cannot be had, and damages for the detention. The only dif-
° Field on the law of dam., sect. 830, Lingle vs Schneider, 30 Wis., 570.
* Hayden y. Anderson, 17 Ia., 158; Warner v. Matthews, 18 IIL. 83;
Rhoads v. Woods, 41 Barber, 471; Fitzhugh v. Wiman, 9 N. Y. 559; Sea-
man v. Luce, 23 Barber, 240; Jennings v. Johnson, 17 Ohio, 154; Noble
v. Eppelly, 6 Ind., 468. The defendant being entitled to the return of the
property, was entitled also tosome amount of damages, but how great
would depend upon his interest in the property, whether as bailee or ab-
solute owner, the time he nad been deprived of it, and its character. 6
Ind., 468; Pierce v. Van Dyke, 6 Hill, N. Y., 613. %
REPLEVIN. 259
ficult point in assessing the damages is to ascertain what ele-
ments are to be considerd in estimating the damages far the
detention. The plaintiff is entitled to recover full compensa-
tion for all the proximate consequence resulting naturally from
the wrongful act. He should in case the property has been
delivered tohim, have judgment for the deterioration in the
value of the goods replevied while they were in the hands of
the defendant, and also for time lost and expense incurred in
searching for his property, and tothe hire of a servant.! The
plaintiff can only recover such expense as arise in the use of
reasonable means to repossess himself of the property, and
will not be allowed to recover expense unreasonably made or
for time spent in making unnecessary searches for the prop-
erty.’,, And he must act in good faith in his efforts to recover
the possession of his property, and will not be allowed to spend
his time and‘money in search of it, merely for the purpose of
increasing his damages against the defendant.
301. Damages where Property is not Returned. In case the
property is not returned to the plaintiff he is entitled toa
judgment for its value at the time of the wrongful taking or
detention, with interest, or any subsequent value to the time of
bringing the suit or the trial of cause, as the courts of the differ-
ent States may hold.
1 Mitchell v. Burch, 36 Ind., 529; Morris on replevin, 193-4; 21 Chitty
Rept. 333. In case where the defendant took the plaintiff’s hogs, and
retained them for several months, the plaintiff testified that he lost two
weeks time hunting his hogs; hands were worth one dollar per day, team
to plow worth one dollar and fifty cents per day, had’ to stop the plow
while hunting the hogs; held that plaintiff could recover damages for
the time lost, 36 Ind., 529. ;
Any deterioration of the goods while in the possession of the defend-
ant, after the unlawful taking is a proper subject of damage.
Gordon v. Jenny, 16 Mass., 470; But after they are restored if they
should be injured, decay, or otherwise impair in value, it must be at the
plaintiff's risk, Ib.
260 LAW OF DAMAGES.
For the detention, the same as given in the preceding sec-
tion.
302 Articles of Peculiar Value. In case replevin is brought
for the recovery of property of peculiar value, the same rule for
the assessment of damages applies as in case of conversion. See
the discussion of the question under the head of trover. See
also the discussion of the question as to when the value of the
property should be considered under the same head.
303. The statues generally provide that where the prop-
erty has been delivered to the plaintiff, and the defendant
claims a return thereof, judgment for the defendant may be for
the return of the property or its value, in case a return of the
property cannot be had, and the damages for the taking and
withholding of the property. The same rule for the assessing
of damages as in the case of detention by the defendant ap-
plies.’
> Tardy v. Howard, 12 Ind., 404; Chesion v. Lamcool, 9 Ind., 530.
CHAPTER XVII.
EMINENT DOMAIN.
THE RIGHT TO TAKE Private Property. How tur Srate
MAY TAKE PROPERTY. THE DAMAGES THAT THE OWNER MAY
RECOVER. THE AMOUNT OF DAMAGES. VALUE OF THE LAND
WHEN A WHOLE TRACT.
304. The Right of a Government to take Property. It is inci-
dent to the sovereignty of any government that it may take
private property for public use. If this was not so, the gov-
ernment would fail to meet the public wants, and to carry out
the object of its creation, for without this power the State
could not establish or open a highway, build a railroad, dig a
canal or turnpike, no ground could be procured on which to
erect public buildings, save by contract with the owner.’ This
1 Waterworks v. Buckhart, 41 Ind., 364. In the case of Kohl et al. v.
United States, which was a case involving the right of the United States
government to exercise the right of eminent domain. Justice Strong
livered the opinion of the court. He said: “It has been seriously con.
tended during the argument that the United States government is with-
out power to appropriate lands or other property within the State for
its own use, and to enable it to perform its proper functions. Such an
262 LAW OF DAMAGES.
power is not conferred by the constitution of the States, but is
generally limited by them.’
305. How the State may Take Property. The State may exer-
cise this right directly, or she may delegate it to corporations,
companies or individuals.’ The right of a government to take
and appropriate the property of citizen is one that should be
watched with great care. And it should never be exercised
except when the public interests clearly demand it, and then
\
authority is essential to its independent existence and perpetuity. These
cannot be preserved if the obstinacy of a private person or if any other
authority can prevent the acquisition of the means or instrument by
which alone governmental functions can be performed. The powers
vested by the constitution in the general government demand for their
exercise the acqnisition of land in all the States. These are needed for
armories and arsenals, for navy yards and for light houses, for custom
house, postoffices and court houses, and for other public uses, If the
right to acquire property for such use may be made a barren right by the
unwillingness of property holders to sell, or by the action of the State,
prohibiting a sale to the Federal Government, the constitutional grant of
power may be rendered nugatory and the government is dependent for
its practical existence upon the will of a State or even upon that of a pri-
vate citizen. This cannot be. No one doubts the existence of the State
government, of the right of eminent domain—a right distinct from and
paramount to the right of ultimate of ownership. It grows out of the
necessity of there being no act of tenure by which the lands are held.
It may be exercised, though the lands are not held by grant from the
government either mediably or immediately and independent of the
consideration whether it would escheat to the government in case of
afailure of heirs The right is the offspring of political necessity, and is
inseparable from sovereignty. * * But the right of eminent domain
exists in the Federal Government. It isa right which may be exercised
within the states as far as necessary to the enjoyment of the power con-
ferred upon it by the constituion. Kohl v. United States,91 U.S. R.,
367; See Ableman v. Booth, 21 How., 523; Cooley on constitutional
limitation, 526. :
* Waterworks v. Burkhart, supra.
® McCormick v. town of Lafayette, 1 Ind., 364; Waterworks v. Burk-
hart, 41 Ind., 364.
EMINENT DOMAIN. 263
~
with great caution. The way it is to be exercised should be
marked out in the clearest possible manner by the. law.’
306. The title the State may in this: way acquire an
easement, an estate for years, for life, or in fee, just at the op-
tion of its legislative body.’ But where an easement is taken,
as isusually done on the establishing of common highways,
the government only acquires the right to use the property for
certain public purposes, and the fee remains in the owner, and
when she ceases to use it for the specified purpose, then the
owner may repossess himself of it again, and the public loses
its interest in the same.’
307. The Damages that the Owner may Recover. The amount
of damages that the owner of the property may recover ‘in
this class of cases must vary with the surrounding circum-
stances and the interest appropriated. If the government ap-
propriate a fee the damages will be greater than if she only ac-
quires a life estate, or an easement. The authorities uniformly
hold that no benefit that the owner of the property may share
in common with the’rest of the inhabitants of the vicinity
shall he taken into consideration in assessing his damages.’
7 Cooley on.court lim., 527.; Deekman v. Mayor, 5 N. Y., 434; Allen v.
Jones, 47 Ind., 438; State v. Bockma, 8 Black, 246; McCormick v. La-
fayette, 1 Ind., 364.
1.2 Kent com., 3 ed.,.340; Beckmon v. Saratoga, etc., R. R. Co, 3 Paige,
73; Warick v. Siaith, 5 Paige, 159, 160; Waterworks Co. v. Burkhart, 41
Ind., 364; Hayward v. the Mayor, 7 N. Y. 314; DeVaraigne v. Fox, 2
Blackf., C. C., 95; Haldernon v. Pa. C RR. 50 Pa st., 425; Rexford v.
Knight, 1 Kernon, 308; Dingly.v. Barton, 100 Mass., 544; Brooklyn Park
Cmo. v. Armstrong, 45 N. Y., 234; Hatch v. Cincinnatti R. R. Co., 18
Ohio st., 92; Cooper v. Williams, 4 Ohio 552; Craig v. Mayor, 53 Pa. st. ,
477; Water Commissioners v. Lawrence, 3 Edw., 552.
2 Waterworks Co v. Burkhart, 41 Ind., 364.
3 Van. & Terre Haute R. R. Co. v. Bowers, 58 Ill., 61; Louisville &
Nashville R. R. Co. v. Glazebrook, 1 Buhs, Ky., 325; Hunt v. Smith, 9
264 é LAW OF DAMAGES.
It has been held where land was taken for railroad pur-
poses, that the owner was entitled to recover: 1, the actual
value of the land taken, without any deduction for benefits;
2, such damages as he actually sustained, resulting imme-
diately and directly from the proper construction of the road,
but not remote or speculative damages; 3, necessary fencing
caused by the construction of the road should be considered;
4, damages to the entire tract caused by the construction of
the road. That benefits peculiar to the owner and not enjoy-
ed by the community in common, should be considered.’
308. The Amount of Damages. In this class of cases the
damages are assessed once for all, and the owner of the land is
entitled to compensation for every injury resulting from the
appropriation. And where a whole of one’s land is taken, its
value at the time of taking is generally the measure of dam-
ages. This rule also applies where an isolated tract of land
belonging to an individual is taken."
Kas., 137, Richmond R. R. Co. v. Burback, 5 Ind., 543; Irom v. Miss.
C. R. R. Co., 5 Ind., 300; Whitewater Valley R. R. Co. v. McClure, 29 Ind.,
536; St. Joseph & Denver R. R. Co. v. Orr, 8 Kas., 419; Giery v. Cin., Wil.
&c. R. R. Co., 4 Ohio st., 308; N.O.G. W.R. R. Co. v. Lagorda, 10 La.,
An. 150; ast ¥. Ss. & St. Paul R. R. Co, 16 Minn., 260; Polernery
same, 508; Brown v. Beatty, 34 Mis, 297; N. J. &G. N. R. R. Co. v.
Maye, 3 Miss., 374; Lee v. Teho & Neosha R. R. Co,. 53 Mo., 178; Home-
stein v. A. & G. W.R. R. Co., 51 Pa. st. 87; Whitmon v. Bastin & Maine
R. R. Co., 3 Allen, 133; same y. same, 7 ib, 313; Little Miami R. R.
Co. v. Collett, 6 Ohio st., 182; Meacham v. Fitchburg R R. Co., 4 Cush.
291; Davis v. Charles R. B.R. R. Co., 11 Cush , 506; B.S. R. R. Co. v.
Budlong, 6 How. prac., 467; Honstur v. A. & G. Ww. R. Co., 51 Pa. st., 87;
D. L. W. RB. R. Co. v. Payne, 16 Barb., 273; A.S.R. RB. Co. v. Dayton,
10 Abbott prac., N. S. 182; Boston R. R. Co. v. Lee, 13 Barb., 169; V.
T. R. R. Co. v. Henry, 8 Neva., 165; W.St. P. R. R. Co. v. Deccan, 10
Minn., 267; 8 Kansas, 409
5 Robbins v, Milwaukee & Harecon R. R. Co., 6 Wis., 636; Elizabeth-
town & Paducah R. R. Co. v. Helmes’ heirs, € Bush, 681.
Where land is taken subsequent to the building of a railroad, its value
at the time of taking is the damages. Stafford v the city of Providence,
10 R. L, 867.
i Montgomery Gravel Road Corp. v. Stockton, 43 Ind, 828; the White-
EMINENT DOMAIN. 265
308. The Rule of Estimating the Damages in case a Part of the
Tract is Taken. The correct-rule for the estimation of the dam-
ages, is to ascertain the value of the whole tract of the owner,
without the right of way, and also what will be the value of
the part not taken, after the appropriation has been made, or
the land not taken together with the damages assessed should
always equal the value of the wh le land immediately before
the appropriation.*
water Valley Co. v. McClure, 29 Ind., 536; Stafford v. city of Providence
10 B. I. 567; Dillon on munic. corp., 487; 52 Ind., 163-229; Freeland v.
N.C. R.R. Co., 4 Jones’ law, 89; Pacific R. R. Co. v. Crystal, 25 Mo., 544;
St. Louis & St Joe R. R Co. v. Richardson, 45 Mo., 466; same v. Robin-
son, ib., 483; W. St. P. R. R. Co. v. Waldon, 11 Minn., 515; Minn. Cent.
R. R. Co. v. McNamara, 13 Minn., 508.
‘Henry v. the Dubuque R. R. Co., 2 Ia., 288; Salter v. Burlington R.
R Co, 11a, 386; Watson v. Pitt. R. R. Co., 37 Pa st., 469; Schuylkill
Nav. Co. v. Sherburne,7S & R., 411; Deaton v. Polk Co., 9 Ia., 594;
Preston v. Dubuque Co., 11 Ia., 15; F. A. & 8. R. R. Co. v. Caldwell, 31
Cal., 367; E. P. R. R. Co. v. Hattenstine, 47 Pa. st., R. 28.
CHAPTER XVIII.
DAMAGES UNDER THE PATENT LAWS.
DAMAGES FoR INGRINGEMENT OF Patents. THE METHOD OF
ASSESSING DAMAGES. THE GENERAL RULE FOR THE AS-
SESSMENT OF DAMAGES. THE METHOD OF ASCERTAINING THE
DAMAGES. THE DAMAGES: GENERALLY ESTIMATED FROM
THE PROFITS. WHERE NOMINAL DAMAGES. RULE OF DAM-
AGES IN EQUITY. CopyRIGHT. THE MEASURE OF DAMAGES.
‘Act oF Conaress. THE DAMAGES. TRADE MARKS PRO-
TECTED AT COMMON AW. THE MEASURE OF DAMAGES.
THE RULE WHEN THE PROFIT CANNOT BE ASCERTAINED.
310. The Government of the United States Frequently Grants
Titles. The Government of the United States frequently grants
to an individual on his application, the exclusive privilege of
making, using and vending, and to authorize others to make,
use and vendan invention. This right is generally granted
by what is called letters patent. If any one infringes upon
the right of the patentee, he can maintain an action to recov-
er damages. And the question as to what shall be the meas-
ure of damages was for years one of great annoyance to the
courts and the members of the legal profession.
PATENT LAWS. 267
311. The Method of Assessing Damages. The Supreme Court
of the United States in commenting on the question, say “It
must be apparent to the most superficial observer of the im-
mense variety of patents issued every day, that there cannot
in the nature of things be any one rule of damages which will
equally apply to all cases. The mode of ascertaining the ac-
tual damages must necessarily depend upon the peculiar na-
ture of the monopoly granted. A man who invents or discov-
ers a new compusition of matter, such as vulcanized india rub-
ber, or a valuable medicine, may find his profits to consist in a
closed monopoly, forbidding any one to compete with him in
the market, the patentee being himself able to supply the’
whole demand at his own price. If he should grant license
to all who might desire his compostion, mutual com petition
might destroy the value of each license. This may be the
case also where the patentee is the inventor of an entire new
machine. If any one could'use the invention or discovery by
paying what a jury might suppose to be a fair value of a li-
cense, it is plain that in such case the profit of the infringer
may be the only criterion of the actual damages of the pat-
entee. But one who invents some improvements in the
machinery of a mill could not claim that the profits of the
whole mill should be the measure of damages for the use of the
_ improvement. And where the profits of the patentee consists
neither in the exclusive use of the thing invented or discovered,
nor in the monopoly of making it for others to use, “it is evi-
dent that the rule allowing damages to the same extent as if
the defendant had pirated the whole machine or invention,
1
does not apply.
312. The General Rule for the Assessment of Damages. But it
‘may now be laid downas a general rule that the plaintiff is en-
1 Seymour & Dayton v. Morgan, 16 How. 480.
268 LAW OF DAMAGES.
titled to recover for the actual loss he has sustained, or that
the patentee may recover the actual damages he has sustained
by the infringement of his right.’
313. The Method of Ascertaining Damages. The mode of as-
certaining the actual damages is given by the court in the case
of Wilber v. Beecher. Justice Nelson said: “Ifthe defendant
has been guilty of violating the plaintiffs right, the rule on
the question of damages is that that the plaintiff is entitled to
all the actual profits which the defendant may have made by
the use of the principle of the plaintiffs combination. In
other words, the plaintiff is entitled to all the damages which
he has sustained by reason of the use which the defendant has
made of the plaintifi’s property. This is in effect the same
thing, because the law presumes that if the defendant had not
put his machine into market the demand would have been for
the plaintiffs, and that he would have received the profits on
the machines which have been made and sold by the defendant.
Vindictive or exemplary damages are not allowed. The jury
are confined to actual damages, and the law has provided that
the court may increase the damages in certain cases.’”
314. The Damages Generally Estimated from Profits. The
usual way of determining the actual damages is to ascer-
tain the amount of the profits received by the unlawful use of
* Field on damages, 574; Phillip on patents, 2; 1 Hill on Torts, 678; Sey-
mour v. McCormick, 16 How. 480, 19 Id. 96, 2 Blatch. 132.
Damages for infringement may be recovered not only where the patent
covers the whole machine, but where it is for an improvement merely.
Seymour v McCormick, 16 How. 480, 19 How. 96. :
“We are of the opinion that where the law gives an action for a par-.
ticular act, the doing of that act imports of itself damages to the party.”
Flint v. Clark, 13 Conn. 861; Whitmore v. Cutter, 1 Gall 429; S. C. Ibd.
483.
2 2 Blatch. 132.
4
PATENT LAWS. 269
the machine or the profits which the party infringing has de-
rived from the use of the invention. The jury should, in as-
sessing damages, take into consideration the price of the ma-
chine, the nature, actual state and extent of the use of the
plaintiff's invention and the particular loss to which he may
have been subjected by the piracy—should all be weighed in
forming the verdict.’
315. Where There is Only an Infringement in the Making, Nomi-
nal Damages. If there has only been an infringement of the
patent in the making of the machine and there has been no
use of it, the jury should assess only nominal damages.’ Re-
mote and consequential damages should not be allowed’ It is
provided by the act of Congress, approved July 8, 1870, that
in this class of cases a verdict is rendered for the plaintiff, the
court may render judgment thereon for any sum above the
amount found by the verdict as the actual damages sustained
according to the circumstances of the case, not exceeding three
times the amount .of such verdict, together with costs.’ But
an application to the court for treble damages, as provided by
this law, should be refused, ‘unless special reasons are shown,
* Buck v. Hermance, 1 Blatch. 398; Parker v. Corbin, 4 McLane 462:
Seymour v. McCormick, 16 How. 480; Stimpson v. the Railroad, Wallace,
Jr., 164; Blanchard v.. Warner, 1 Blatch. 258.
In settling the account between the patentee and an infringer of his
letters patent, the question is not what profit the latter made in his busi-
ness or from his manner of conducting it, but what advantage he derived
from the use of the patented invention. Russel v Place, 94 U.S 606.
5 Whitmore v. Cutter, 1 Gall 481; Keenas v. Schuylkill Bank, 4 Wash.
14. <
6 Carter v. Baker, 4 Fish (P. C.) 404.
7 Act of July 8, 1870, sects. 55-59.
The rule of law as to damages when an infringement is made out, is
to give the plaintiff the actual loss which he has sustained and nothing
more. Exemplary or vindictive damages cannot be given. If the dam-
ages are insufficient there is a provision of law authorizing the. court to
treble. Hall v. Wiles, 2 Blatch. U. 8. 0. C. 194.
270 LAW OF DAMAGES.
such as malice and insufficiency of the verdict.”" The eourt
will, in certain cases where the defendant has been guilty of
an infringement of a patent and the circumstances are such
that the court deem it proper that the defendant should render
an account of the articles manufactured, order him to do so.’
316. The Rule of Damages in Equity. In cases where profits
are the proper measure of damages it is the profit which the
infringer makes or ought to make which governs, and not the
profits which the plaintiff can show he might have made.
But profits are not the primary or true criterion of damages
for infringement in an action at law. That rule applies emi-
nently and mainly to cases in equity, and is based upon the
idea that the infringer shall be converted into a trustee as to
those profits for the owner of the patent which he infringes—a
principle which it is very difficult to apply in a trial before a
jury, but quite appropriate in reference to a master who can
examine the defendant’s books and papers and examine him on
oath, as well as all hig clerks and employes. The sales of
license of machines or of the royalty established constitutes
the primary and true criterion of damages in an action at law.®
317. The remedy for the infringement of a copyright is
an action for damages. The plaintiff in order to make out his
' Schwazel v. Holenshade, 3 Fish (P. C.) 116.
» Holland v. Fox, 25 Eng. L. & Eq. 69; Field on the law of dam., 580.
The courts ha ing jurisdiction of cases under this law may grant an
injunction restraining the defendant from violating the law and infring-
ing on the plaintiff’s rights. Sect. 4921; U. 8 st. at large, 206.
* Burdell v. Dening, 92 U.S. R. S C.716.
The nature and price of the machine should be considered among
the damages. Opinion of Story in Early v. Sawyers, 4 Mason 14. ©
If, on the trial, the evidence shows the defendant has been guilty of
infringing the patent, the court may, if it sees proper, order him to ren-
der an account of the articles manufactured by him in violation of the
PATENT LAWS. 271
case must show that he has complied with the acts of Congress
bearing on the subject; but a copy of the book and the certifi-
cate of the Librarian of Congress will be prima facie evidence
of that fact.’
318. The Measure of Damages.’ As to the measure of dam-
ages in case of an infringement of the author's rights, it is
provided by an act of Congress, that “Every person, who, af-
ter recording the title of a book, as provided by this chap-
ter, shall within the term limited and withont the con-
sent of the proprietor of the copyright first obtained in writ-
ing, signed in the presence of two or more witnesses; print,
publish or impart, or knowing the same to be so printed, pub-
lished or imparted, shall sell or expose for sale a copy of such
book, shall forfeit every copy thereof to such proprietor, and
shall also forfeit and pay such damages as may be recovered in
a civil action by such proprietor in any court of competent ju-
risdiction ’* It will be seen by the reading of this act that it
expressly provides that the defendant may recover such dam-
ages as may be recovered in a civil action. But it is not to be
presumed that Congress intended by this act that the plaintiff
should recover damages whether he had sustained aloss or not.
It simply authorizes the injured party to commence a suit,
and leaves the question of damages to be determined by a
jury in accordance with the rulesof law. And it is clear that
under this provision of the law the plaintiff may recover.dam-
ages for the actual injury sustained and the books forfeited.‘
319. Itis provided by the same act, that “If any person
after the recording of the title of any map, chart, musical
plaintiff's right and account for the value of those sold by him, also for
the value for such as he may have on hands. Holland v Fox, 25 Eng.
L. & E. 69; Hubble v. United States, 13 Court of C. 1.
12 Greenleaf on evid., 511. 3
3 Act of July 8, 1879, chap. 230, sect. 90.
+ Field on the law of dam., 582, Sect. 721.
272 LAW OF DAMAGES.
composition, print, cut, engraving, or photograph, or chromo,
or of the description of any painting, drawing, statue, statu-
ary, or model or design intended to be perfected and executed
as a work of the fine arts, as provided by this chapter, shall
within the term limited and without the consent of the pro-
prietor of the copyright first obtained in writing, signed in
the presence of two or more witnesses, engraving, etch work,
copy, print, publish or impart, either in whole or in part, or
by varying the main design with intent to evade the law,
or knowing the same to be so printed, published or imparted,
shall sell or expose for sale, any copy of such map or other ar-
ticle aforesaid, he shall forfeit to the proprietor all the plates
on which the same shall be copied, and every sheet thereof, ei-
ther copied or printed, and shall further forfeit one dollar for
every sheet of the same found in his possession, either print-
ing, printed, copied, published, imported or exposed for sale,
and in case of painting, statue or statuary, he shall forfeit ten
dollars for every copy of the same in his possession, or by him
sold or exposed for sale, one half thereof to the proprietor and
the other half to the use of the United States.”* It is pro-
vided further by said act, that “Any person publicly perform-
ing or representing’ any dramatic composition for which a copy-
right has been obtained, without the consent of the proprietor
thereof, or his heirs or assigns, shall be liable for damages, in
all cases to be assessed at such sums not less than one hundred
dollars for the first, and fifty dollars for every subsequent per-
formance, as to the courtmay appear just.”> These provisions
will not be so construed as to make any quotation or sentence
that may be found in the defendant’s work, a violation of the
the plaintiffs copyright. “If the main design be not copied,
the circumstance that a part of the composition of one author
is found in another, is not of itself piracy sufficient
‘ Sect. 4965, U. S. st., states at large.
5 Sect. 4906, U. 8. st., states at large.
PATENT LAWS. 273
to support an action.”* Nor will the fact that that the
new publication is prejudicial in some degree to that of the
plaintiff enable him to maintain an action. In order for the
plaintiff to sustain his action he must show that the defend-
ant’s work is substantially a copy ora colorable selection or
abridgment of his work. The greatest difficulty generally
lies in what is called the middling class of cases, where there is
only a part of the plaintiff's work taken, in this case the
question to be determined is “whethes it isa legitimate use of
the plaintifi’s publication in the fair exercise of a mental op-
eration entitling it to the character of an original work.”’
319. The Damages. The same damages can be recovered
in these cases by the plaintiff that can be in an action fora
violation of patent laws,? (which see). The plaintiff can re-
cover his actual loss.
,
820.° Trade Marks.—The Common Law Rule. The common
law protects an individual in the use of whatever trade mark,
sign, brand, label, words, or other devices that he may adopt to
designate the article of his make or manufacture. They are
treated as the private rights of the originator, and if there is a
violation of his right he can recover damages for whatever in-
jury he may have sustained. There is an act of Congress pro-
viding that if a trade mark is duly registered, that the exclus-
ive right to use it shall remain in force for thirty years.’
2 Greenleaf evid., sect. 514.
, 2 Greenleaf evid., sect. 514.
2 Field on the law of dam., 583. .
1 Taylor v. Carpenter, 11 Paige 292; Graham v. Plate, 40 Cal.; Marsh
v. Billings, 7 Curtis, 322; Slack v. Landgraf, 17 Barb., 608; Christy v.
Murphy, 12 How. prac., 78; Coruw v. Derby,
*16 U.S. st., 210; Res. st, sects. 4937, 4941; McClane v. Fleming, 96
U.8., 245. (Since writing the above the Supreme Court of the U.S.
have pronounced this law unconstitutional. Cent. Law Journalof Dec.
274 LAW OF DAMAGES.
Whatever name or device a party may adopt to advertise his
business, he by adopting and using it acquires a right thereto,
and may recover damages from any one who uses it to his in-
jury. In order to acquire the exclusive right to use a trade
mark, it must be one that denotes the goods, ownership, place
of business, and kind and quality of the article in which the
party deals.’
320. The Measure of Damages. In this as in all other ac-
tions in tort, the rule of complete compensation for all injuries
is the true measure of damages.’ It is sometimes quite diffi-
cult to arrive at the exact damages that the owner of the trade
mark has sustained by reason of the infringement or the de-
fendant’s wrongful use of his property, and courts have adopt-
ed different methods for this purpose. The general rule for
damages is the profit the defendant has made by the use of the
trade mark, or what he ought to have made, together with the
5, 1879, page 449.) Sykes v. Sykes, 3 B. & C. 411; Rodgers v. Nowell, 5
M. G. & Scott, 109; Holloway v. Holloway, 13 Barb., 209; Burgess v.
Burgess, 17 Eng. L. & E., 257; Clark v. Clark, 25 Barb , 79; Schueltzer v.
Atkins, 46 L. & R., chys. 780; James v. James, L. R., 13 Eq. case 421;
Wolfe v. Burke, 7 La., 151; Meneely v Meneely, 3 N. Y., 540; Gilman
v. Hunnell, 122; Morgan v. Schmackhofer; 55 How. N. Y. prac., 37; Dun-
bar v. Glen, 42 Wis., 113; Deelim v. Deelim, 67 Barber, 290; McClane
v. Fleming, 96 U. 8. 245; Coats v. Holbrook, 2 Sandf. ch. 586; Colladay
v. Baird, 4 Phil., 189; Holloway v. Holloway, 13 Barb., 209; Boardman
v. M. B. Co., 35 Conn., 418; Walton v. Crowly, 3 Blatch., 440; Emener
v. Badger, 101 Mass., 82.
* Ferguson v. Daniel Miller, 2 Bruce, 314; Stonebraker y. Stonekraker,
33 Md., 252; Hortter v. Vansickle, 1 Dill 329; Menlue v. Menlue, 12 Ala.,
L. J., 22. Elsewhere courts of justice proceed upon the ground that a
party has a valuable interest in the good will of his trade, and in the la-
bel or trade mark which he adopts to enlarge and perpetuate it. Hence
it is held that he as a proprietor is entitled to protection, as against one
who attempts to deprive him of the benefit resulting from the same by
using his name and trade mark without the consent of the author.
Meneely et al v. Meneely, 62 N. Y., 427.
* Field on the law of dam , 587; Taylor v. Carpenter, 2 Wood & M., 1;
Colt v. Hollerook, 2 Saund., ct. 586.
PATENT LAWS. 275
damages, if any the plaintiff has sustained by having the
credit of his trade mark reduced, and the injury he may have
sustained by the introduction of the spurious article in the
trade. This is perhaps as correct a rule as can be laid down in
this class of cases. While the profits made by the defendant
does not limit the recovery, the owner of the trade mark is en-
titled to all the profits which the defendant realized.
321. The Rule where the Profits Cannot be Ascertained. It some-
times happens that from the very nature of the case it is im-
possible to ascertain how much of the profits result from the
intrinsic value of the commodity in the market, andhow much
from the credit given to it by the trade mark, where the prof-
its produced by the trade mark, and from the intrinsic value
of the commodity, cannot be separated, then a question that
is not free from difficulty arises as to how the damages.are to
be estimated. Following a principle laid’ down by law writers
in cases of confusion of goods by a wrong doer, the owners of
the trade mark would be entitled to the whole of the profits.‘
And where the proof showsthat a violation of the right to use
is shown and there is no proof of damage, the plaintiff will be
allowed nominal damages.’ The defendant may show in miti-
gation of damages that he was ignorant of the plaintiffs right
to use the mark.§
* Graham v. Plate, 40 Cal., 593.
5 Burnett v. Pharlan, 21 How. prac., 157; Blackfield v. Payne, 4 B. &
A., 410.
6 Faber v. Dunty, 11 Able. N. Y. pract., 399.
CHAPTER XIX.
PUBLIC OFFICERS.
Tue Opsect oF A Court. THE Division oF AUTHORITIES.
THE RESPONSIBILITY OF A JUDICIAL OFFICER. THE MEAS-
URE OF DAMAGES. MINISTERIAL OFFICER. HIs RESPONSI-
BILITY. EsScAPE OF A PRISONER. PResuMPTIONS. EXEM-
PLARY DAMAGES. MITIGATING CIRCUMSTANCES. ATTOR-
NEYs. THEIR RESPONSIBILITY.
322. The Object of a Court. The object of a court is to set-
tle in an impartial manner, controversies between individuals.
And itisa principle that lays at the foundation of all well
organized jurisprudence, that every judge, whether of a high
or lower court, exercising jurisdiction vested in it by law,
and deciding upon the rights of others, should act upon his
own free unbiased conviction, uninfluenced by any apprehen-
sion of consequences. And it is well settled that no judicial
officer will be held responsible for error of judgment in render-
ing his opinion, if it appears that he had jurisdiction of the
person and subject matter, and this rule applies as well to jus-
tices of the peace as to the higher courts.?
» Pratt v. Gardner, 2 Cush., 68-70; Hall on torts, 164; Airie v. Sedg-
wick, 2 Roll Rep. 195-197; Miller v. Sears, et al., 2 Blackf., 1145; Maston
v. Holsey, Ib. 1147.
PUBLIC OFFICERS. 277
298. The Division of Authorities. The authorities are very
mauch in conflict upon the question of the liability of a judic-
ial officer for fraudulent, corrupt and malicious conduct while
acting within the scope of his authority. Some hold that the
motives that prompted him in rendering his decision ina
cause cannot be inquired into.’ While others hold that he
should be held responsible for all injuries to litigants and third
parties, arising from his fraudulent, corrupt and malicious
conduct.t To hold a judicial officer responsible for his decis-
ions and conduct while acting within the province of his au-
thority is to open the door to almost endless litigation. And:
to say that he should answer in damages only tor those fraud-
ulent, corrupt and malicious acts resulting in injury to others,
has no tendency to prevent litigation from the fact that the
losing party could allege that the judge who presided at the
trial acted fraudulently, corruptly and maliciously in all his
rulings on the trial of the cause.*®
324. Where Officers have no Jurisdiction they are Responsible.
While a judicial officer is not responsible for misconduct, mis-
take of judgment, or erroneous decisions, they are liable for
trespass committed under color of authority. And where his
jurisdiction is special and limited, and he transcends his au-
thority and acts in a case in which he had no cognizance, his
3 Hill on torts, p. 162; Pratt v. Gardner, 2 Cush., 68-70; Durtrich Y,
Schell, 12 Mass., 506; Elder v. Morris, 10 Wend.; 128; Bullett v. Clem-
ent, 10 B. Monroe, 693; Taylor v. Moffett, 2 Blackf., 305; Burly v. Beth-
im, 3 Iowa, 580; Doer’s case in error, (Conn.) 315; Bernard v. Hoffman,
18 Md.. 479.
* Bernard v. Hoffman, 18 Md., 479; Bullett v. Clement, 16 B. Monroe,
193; Gregory v. Brown, 4 Bib., 28; Margan v. Dudley, 18 B. Monroe, 693;
Morgan vy. Hughes, 2 T. K., 225; Burly v. Bethim, 5 Iowa, 580; Field on
law of dam., sect. 760.
5 Pratt v, Gardner, 2 Cush., 68-70.
278 LAW OF DAMAGES.
proceedings will be coram non judici, and void, and no person
much less a suitor can justify under them.°
325. The Measure of Damages. The rule of full and complete
compensation for all injuries resulting from the wrougful act,is
the measure of damages. This rule applies to injury to person
and property, except in case where exemplary damages are au-
thorized. “If the injury resulting from the fraudulent, cor-
rupt and malicious act of the judicial officers was imprison
ment, then the general rule of damages, as laid down in our
chapter on False Imprisonment applies. But if the injury
was tothe property of the plaintiff, then the rule in our chap-
ter on Trespass, applies.
326. Ministerial Officers. Suits are frequently brought
against constables, sheriffs, marshals and other ministerial of-
ficers for neglect to perform their duties in the service of legal
processes. The most frequent suits in this class of cases are
those brought by judgment creditors against such officers for
failure tolevy executions and writs of attachment on property
and to sell the same according to law, or a failure to make the
return required.
327. . The Damages. The actual damages to a judgment
creditor, where a constable, sheriff or marshal fails to levy an
execution or a writ of attachment on property and expose it
6 Taylor v. Moffatt, 2 Blackf., 305; Blood v. Sayer, 17 Vt., 609; Cabel
vy. Cooper, 15 Johnson, 157; Holton v. Smith, 14 Adl, & Ell. (N.S ) 840;
Pease v. Clayton, 1 Best & S. 658; 2 Hill on torts. 174-175; Field on the
law of dam., sect. 160.
A judicial act is an act performed by a court, touching the right of
parties or property brought before it, by voluntary appearance or by
prior action of a ministerial officer, in short by ministerial acts. Flour-
noy V. the city of Jeffersonville, 17 Ind., 169; Walldo v. Wallace, 12 Ind.,
569.
PUBLIC OFFICERS. 279
to sale are suchas the goods would have sold for at public aue-
tion, not exceeding the amount of the plaintiffs judgment or
debt. Ifthe action is brought against the constable, sheriff or
marshal for failure to levy the writ upon property belonging to
the judgment defendant, and the property that he might have
but neglected to levy upon, was equal to or exceeded in value
the plaintiff’s judgment, then the measure of damages should
be the amount of the judgment and interest.!
328. Property taken not subject to Execution. Where property
is taken by a constable, sheriff or marshal, on execution or
other writ, that is exempt from sale on execution, or which
belongs to a third person, the damages will be the same as in
replevin or trover.
329. Escape of a Prisoner. The law allowing imprison-
ment for debt has been abolished in most, if not all, of the States,
and now about the only way that a person can be imprisoned
for debt ison capias. This keeps up the demand for the old
rule for the assessment of damages in case of a negligent es-
cape. The Supreme Court of theState of Ohio in comment-
ing on this question lays down the rule in a clear and forc-
ible manner as follows: 1, “On proving the judgment, ar-
_ rest and escape, the plaintiff is prima facie entitled to récover
the whole amount of his debt.” 2, “To reduce the amount of
' Field on law of dam., 611; Burton v. Fulton, 49 Pa. st,, 151; Mullett
yv. Chollis, 39 Barb, 69; Perkins v. Pitman, 2 Eng. L. & E., 260; 10
Wend. 367; Bowman v. Crowell, 39 Barb., 69; Smith v. Took, 20 Texas,
750; Clarke v. Miller, 47 Barb., N. Y., 38; Hays v. Porter, 22 Me., 371;
Bickford v. Hood, 7T. H., 620; Farmer v. Turnpike Co., J Coventry, 10
Johnson, 389; Pugh v. McRae, 2 Ala., 393; Clark v. Smith, 40 Conn., 1;
Hamilton v. Marsh, 2 Tyler )Vt.), 403; Arnold v. Commonwealth, 8 B.
Monroe, Ky., 109; Marshall v. Simpson, 13 Ala., 437; Danforth v. Pratt,
9 Cush., 318; Hudson v. Wilkint, 7 Me., 113; Ackley v. Chester, 5 Doy
Conn., 221; Hammer v. Griffith, I Grant (Pa) Con., 193; Barrett v.
Reed, 51 Pa. st., 190.
280 LAW OF DAMAGES.
the recovery below the amount of debt due from the escaping
prisoner, the onus probandi rests upon the defendant.” 3, “For
this purpose the defendant may not show that the amount of
the debt isstill capable of being collected from the escaped
prisoner, but may show his partial or total insolvency or
pecuniary worthlessness at the time of the escape.” 4, “That
on proving judgment, arrest and escape, the plaintiff in all
cases is entitled to nominal damages.” 5, “Wherea jury finds
the escape to have been not only voluntary on the part of the
officer, but that in permittIng he was actuated by fraud, mal-
ice or corruption, they are not restricted in the amount of the
injury actually sustained, and may include reasonable exem-
plary damages, but with this exception, where evidence in
mitigation is given the actual injury sustained, is the proper
measure of damages.” .
330. Presumptions. The law raises a presumption in! fa-
vor of an officer and that he has discharged all his official du-
ties.» And where attached goods are lost in an action against
the officer, the loser if he can show such a state of circum-
stances as to overturn all presumption of negligence, the bur-
then of proof will then rest on the plaintiff, and in case of loss
by theft it has been held that it was not even presumption of
negligence.
331. Exemplary Damages. The rule which allows exem-
plary damages applies to ministerial officers as well as to other
persons. A ministerial officer is not responsible for any act
done in accordance with the law of the State in which he of-
ficiates. But when he violates the law his official authority
is no protection to him whatever, and he is responsible like
2 Hartman v. Shriner, 15 Ohio st., 43; Field on the law of dam., 3770.
5 State v. Freeman, 8 Ohio, 428,
4 Mills v. Gilbert, 47 Me., 320.
PUBLIC OFFICERS. 281
any other individual, for the damages resulting from his un-
lawful act. And where the evidence discloses the fact that he
has been guilty of actual malice, fraud or oppression, the jury
will not be confined in assessing damages to actual compensa-
tion, but may give exemplary damanes.®
332. Mitigating Circumstances. In actions against public
officers for wrongs or torts, as we have already said, they are
held responsible for the injuries and consequences resulting
from their unlawful acts the same as other persons. And as
the motives that actuate a party in the commission of a wrong
is always proper for the jury to consider in assessing damages
in this class of cases, the defendant will be permitted to rebut
the presumption of malice, by showing that he acted inno-
cently and in the honest belief that he was authorized todo
the act complained of. Thus in an action against a sheriff or
constable for seizing and selling goods of the plaintiff on ‘an exe-
cution against another party; the sheriff or constable may show
in mitigation of damages that the goods were bought in by the
plaintiff at an under price.6 As arule a sheriff or constable
who has wrongfully levied an execution upon goods of the de-
fendant in the execution, cannot generally show in mitigation
of damages that he has applied the proceeds of the sale to pay-
ment of the debt of the plaintiff.’ In the case of McMichael
5 Hunter v. Bacon, 15 Conn, 271. See also ante. page on exemplary
damages. Field on the law of dam., sect. 771.
* Forsyth v Palmer, 18 Pa. st., 96; Baker v. Freeman, 9 Wend., 36;
Clark v. Hallock, 16 Wend., 607; Alexander v. Helber, 35 Mo., 334. ;
7 Forsyth v. Palmer, 18 Pa. st., 96; Baker v. Freeman, 9 Wend., 36;
Clark v, Hallock, 16 Ib., 607; Alexander v. Helber, 35 Mo., 334; Mc-
Michael v. Mason, 13 Pa. st. 214; Ohio v. Jones, 21 Wend., 594, Hopple
v. Higbee, 3 Zab. N. Y., 342; Hill v. Loomis, 6 N. H., 268. In Alabama
in an action against the sheriff for the wrongful levy on property of the
plaintiff on an execution against another person, the fact that the goods
were in the possession of the defendant at the time of the levy may be
shown in the mitigation of damages.
282 LAW OF DAMAGES.
vy. Mason it was held that in trespass for taking on execution
a debtor’s only cow, which was exempt, the plaintiff was held
entitled to recover the value of the cow, although the proceeds
of thesale of thecow had been applied in satisfaction of the
execution."
333. Attorneys, their Responsibility. Attorneys are a class of
judicial officers, and it is awell settled rule of law that an at-
torney is always responsible in consequence of his ignorance,
carelessness, or want of skill in the transaction of his client’s
business, or in the trial of his cause. The task of an attorney
to always determine, in 4 critical case, the proper steps to be
taken in its prosecution or defense, is sometimes very difficult.
A small circumstance, a slight injudicious movement, some-
times has.a tendency to injure his client’s cause. In such
cases he should advise his client to the best of his judgment,
and where there is a doubt in his mind as to the best course to
pursue or what should be done in order to be safe, he should
follow the advice and wishes of his client, and if he fails to do
so and his client sues for damages, if he can show that the fail-
ure of the attorney to carry out his wishes has injured him,
he can recover damages for that injury.’
334. The Measure of Damages. The general rule of full
compensation for all actual loss sustained by the client on ac-
count of the negligence and want of knowledge and skill on
the part of his attorney, as a rule will be the damages.’ The
attorney may show in mitigation of damages where he is sued
for neglecting to order an execution, or to exercise proper dili-
gence in looking after his client’s claim, that the execution de-
' Ala , see case 404, Sterrett v. ex. r. v. Kaster.
° Nam v. Baird, 12 Ind., 318; Reilly v Cavanaugh, 29 Ind,, 435; Cox
v. Sullivan, 7 Ga., 144; O’Barr v. Alex, 37 Ga., 195; Holmesv. Peck, 1 R. °
I., 242; Nelson v. Russ, 19 Me., 44; 2 Hill on torts, 480-484.
PUBLIC OFFICERS. 283
fendant has plenty of property out of which the plaintiff's
claim can be made.
335. Damages for being kept out of Office. The amount of dam-
ages that a legally elected officer may recover, who has been
wrongfully kept out of his position of trust is not well settled
by the authorities. But there are familiar principles that will
assist us-in arriving at a definite conclusion upon the question.
The old remedy for deseizin of office of profits seem to have been
by assizes, and the suit was allowed by analogy to proceeding
for the recovery of possession of real property and its appurten-
ances. And in such actions the courts will not permit any de-
duction on account of the personal service of the defendant.
And in an action for mean profits the defendant can not show
in order to reduce the plaintiff’s recovery that he has made more
money in any other business, than he couldby farming. And
inno case will a trespasser be allowed for his services in clear-
ing the land which he wrongfully withholds from the true ow-
ner. There is a principle in law that where the labor of one
inures to the benefit of ‘another the defendant will be liable on
an implied contract to pay forthe labor. But this rule only
applies where the labor is done under such circumstances as to
raise a presumption of consent on the part of the employe,
and never applies where the labor is performed against the will
of the defendant or the supposed employe, for no rule of law
will permit one to make another his debtor in spite of his pro-
test and against his will. And where one unlawfully keeps
another out of an office to which he has been duly elected or
appointed, and suit is brought for damages, the plaintfff can re-
cover the full amount of his salary for the time he has been
® Hill on torts, 478 et seq 4 ed.; Governor v. Raly, 34 Geo., 175; Hoby
v. Built, 3 Born & Adel., 350, pr. ld. Mansfield; Pitt v. Yalden, 4 Burr,
2961; Field on the law of dam., sect. 775; Glasscock v. Lyons, 20 Ind., 1;
Douglas v. the State on the relation of Wright, 31 Ind., 429.
284 LAW OF DAMAGES.
kept out of office. And the defendant can not set off against
his claim the price of his labor for performing the duties of the
office while he wrongfully kept the plaintiff out of possession.’
1 People ex rel. Benott v. Miller. 24 Mich., 458, 9 Am. Rep., 131.
CHAPTER XX.
NOMINAL DAMAGES.
Nomina, Damages. Wuen THEY MAY BE ALLOwED. ALLUW
IN ALL CASES WHERE A RIGHT HAS BEEN EVADED. ALLOW
IN CASE FOR BREACH FOR LABOR. IN CASES OF BANKERS.
IN covENANT. THE SUPPOSED HARDSHIP OF THE RULE.
336. Nominal Damages. As we have already said, the law
affords a remedy for every injury that one may receive in per-
son, property or reputation. Therefore, whenever an injury
is done to the legal right of another, the injured party has a
remedy for damages sustained. And where there is a breach
of agreement or the evasion of a right established, the law in-
fers some damages to the plaintiff, and where there is no evi-
dence introduced showing the amount of the loss the law au-
thorizes the court to declare the right by awarding nominal
damages, being some very small amount, as one cent."
Ld. Holt in Ash v. White, 1 Salk., 19; Sedgwick on the measure of
dam., 44; Field on law of dam., 679; Fullmon v. Stearns, 30 Vt., 443; Whit_,
more v. Cutter, | Gall., 429; Paul v. Sloson, 22 Vt., 231; Whipple v.
Cumberland Mfg. Co., 2 Strong, 661; Bagby v. Harrass, 9 Ala., 173;
Brown v. Davis, 15 Cal., 9; Deuendorf v. Werf. 42 Barb., 227; Bond v.
Hilton, 2 Jones, (N. C.) L. 149; Seal v. Morland, 7 Hump., 575.
286 , LAW OF DAMAGES.
337. When Nominal Damages may be Recovered. The plain-
tiff may recover nominal damage where property is delivered
and accepted, pending asuit in reference to title before verdict.
In an action against a sheriff who failed to levy an execution
issued on a judgment recovered against a certificated bankrupt
for debt due before the bankruptcy.’ Wherea case is submitted
upon an agreed statement of facts but without an agreement
respecting damages. For'a brecch of an agreement for good
consideration to withdraw a suit without proof of actual dam-
ages.» For injury arising from the neglect of a common car-
rier where no loss is established. From a breach of covenant
of warrant where there has been no eviction.’
338. In an action for a breach of an agreement to convey
real estate where no want of good faith appears, the vendor
being unable to make a good title and nothing having been
paid by the purchaser, nominal damages may be recov-
ered? It may be laid down .as ageneral rule that nom-
inal damages will be allowed in all cases where a breach of
contract is shown but no evidence is introduced to establish
the loss. And this. rule applies to both expressed and im-
plied contracts. As the only difference in an expressed
and an implied contract isin the mode of substantiating it.
An express contract is proved by an actual agreement, an im-
plied contract by circumstances and the general course of deal-
ing between the parties. But whenever 4 contract is once
proved the consequences resulting from a breach of it must be
5 Conroy v. Flint, 5 Cal., 327; Selfridge v. Lithgom, 2 Mass , 374.
+ McNeany v. Jewett, 10 Allen, 151.
§ Hogan v. Riley, 13 Gray, 515.
* Southern R. R. Co v. Kendick, 40 Miss., 374.
7 Measely v. Hunter. 18 Mo., 103.
1 Conger v. Weaver, 20/N. Y., 140.
NOMINAL DAMAGES. 287
the same, whether it be proved by direct or circumstantial evi-
dence.”
339. Allow in All Case where a Right has been Evaded. And
that in all cases where the evasion of a right is shown, either
by misfeasance, nonfeasance, or malfeasance, the injured party
has aremedy for damages sustained. And whenever the fact
- is established that the plaintiff has sustained an injury, thelaw
presumes or implies damages; and where there is no proof of
loss the party injured is entitled at least to nominal damages.”
Thus in an action for a breach of an agreement to exchange
farms, in the absence of any showing that the plaintiff had
paid any part of the consideration money, parted with any-
thing, or put in any worse condition than he would have been
in had not the allegations of false representation been made, the
court held that the plaintiff could recover only nominal dam-
ages.*
340. Nominal Damages in Case of a Suit for Labor. Where a
plaintiff sues for wages and proves that he performed labor,
but omits to prove the value of it, he can recover at least nom-
inal damages. “No proprietor has a right to the water of a
running stream to the prejudice of other proprietors above or
below, unless he has a prior right to divert it, or title to some
exclusive enjoyment. Without the consent of the a joining
proprietors he cannot divert or diminish the quantity which
would otherwise descend to the proprietor below, nor throw
the water back on the proprietor above, without a grant
2 Marzette v. Williams, 1 Barn & Adol., 415-541; Smith v. Whiting, 100
Mass., 122; Rosenbaum v. McThomas, 34 Ind., 331; Dormon v. Ames, 12
Minn., 451. °
3 Whittemore v. Cutter, 1 Gall., 429; Paul v. Sloson, 22 Vt., 231; Full-
mon v. Stearns, 30 Vt., 443; Champion v. Vincent, 20 Tex., 811.
4 Frese v. Cary, 29 Ind., 524.
288 LAW OF DAMAGES.
or an uninterrupted enjoyment for twenty years.”° Therefore,
where suit is brought to recovet damages for diverting water
from its channel, or stopping the flow, or for backing it upon
another’s mill or premises, if the facts of diverting, etc., are
established and there is no proof of loss the plaintiff is entitled
to nominal damages."
341. Nominal Damages in a Breach of Covenant. Ina breach.
of covenant of seizin by a vendee who is in possession, nomi-
nal damages can only be recovered ‘unless the plaintiff shows
an eviction."
342. In Case of a Banker. Where a banker receives a sum
of money belonging to his customer he becomes his debtor the
moment he receives it, and is bound to pay a check drawn by
such customer, after the lapse of such a reasonable time as
would afford an opportunity to investigate the account of the
party and to ascertain whether the drawer has any money in
the bank or not, and if in action against the banker for fail-
ing to honor a check drawn on him by the depositor, the plain-
tiff, where no actual damages are shown, is entitled to nominal
damages.
343. Ina Covenant. Where a grantor in a conveyance
stipulated that the purchaser should have a specified time for
the payment of an existing mortgage, and also agreed to pay
the first instalment of the mortgage, and to indemnify the pur-
chaser for any damages for a breach of these agreements. Ina
Owen v. Riley, 2 Mo, 203.
63 Kent, p. 439.
" Munroe v. Stickey, 48 Mo., 462; Munroe v. Gates, 48 Mo. 468; Stow-
ell v Lincoln, 11 Gray, 434; Cory v. Silcox, 6 Ind., 39.
7 Nooman vy. Ilsby, 22 Wis., 27; Marzetta v. Williams.
i Barn. v. Adol., 415-541.
NOMINAL DAMAGES. 289
suit for a breach it was held ‘that the plaintiff might recover
nominal damages though no actual damages were shown.!
342. The Supposed Hardship of the Rule. The rule allowing
the recovery of nominal damages at first view looks like a
departure from the long and well settled maxims that the
law “regards not as mere trifles,” De minimis curiat Lex. But
we should keep in view the fact that the importance of a
law suit is not always to be determined by the amount of
damages that may be recovered. There are many cases
brought, where the amount of damages cannot exceed a
nominal sum that affect the dearest interests of the parties
litigant. But courts should be careful not to enforce the rule
to such ‘an extent as to encourage useless and malicious ©
litigation and legal strife over small, insignificant, and
trifling matters. The rule when properly guarded has a ten-
dency to promote the ends of justice, and is now recognized by
1 Loin v. Archer, 12 N. Y., (2 Kern) 277.
In an action to recover damages for flowages, if the damage is so
small that it cannot be estimated, the plaintiff under the rules of the
common laws is entitled to nominal damages.
Cory v. Sileox, 6 Ind., 39; Wright v. Storm, 4 Jones, (N. C.) L. 516;
Little v. Stanbock, 36 N. C., 285.
+ “There are some injuries of so small and little consideration in law
that no action will be for them; for instance, in respect tothe payment of
tithes, the principle which may from the cases appear to be that for
asmall quantity of corn involuntarily left in the process of raking, tithes
shall not be payable, unless there be a particular fraud or intention to
deprive the person of his full right.” Brooms legal maxims, 143; Paul
v. Sloson, 2 Vt , 231; Williams v. Morty, 4 Vt., M. & W., 144; Field on
law of dam., 682.
2 Sedgwick on the measure of dam., 44, Waterer v. Freeman, Hobart,
266; Strong v. Kearn, 13 Irisn law, 93; Smith v. Whiting, 100 Mass., 122;
Rosenbaum v. MeThomas, 34 Ind., 331; Burnap v. Wight, 14 IIl., 301;
Hutchinson v. Schimmefelt, 40 Pa., 396! McConnell v. Kibbe, 33 IIl.,
175; Shannon, v. Burr, 1 Hilt, 39; Comly v. Davidson, 10 Minn., 392;
Queen v. Moore, 15 N.-Y.,(1 E. P. Smith,) 432; Hope v. Alley, 9 Tex.,
394; Bond v. Hilton, 3 Jones (N. C.) L. R., 149; Ledbetter v. Morris, 3
290 LAW OF DAMAGES.
the courts of this country and England, and is upheld by the
rules of equity and justice.’
id., 543; Kimel vy. Kimel, 4 id., 121; White v. Griffin, id. 139; Amoskeag
Manfg. Co. v. Goodale, 46 N. H., 53; Dorman v. Ames, 12 Minn., 451;
Nosatti v. Page, 10 C. B. R., 643, sc. Eng. law and eq., 326; Bank v.
Tencka, 48 N. Y. 305; Deuendorf v. Wert, 42 Barb., (N. Y.) 227; Basset
v. Saulsbury Mfg. Co., 8 Fost., 438; Brown v. Watson, 47 Me., 161; 10
Fost., 478; Wells v. Walting, 2 W. Blackf., 1233, 9 Co., 113; Pendar v.
Wadsworth, 2 East , 154; 2 B. & Cres., 145; 12 Adons v. Ellis, 488; Moor
& M., 172; Cory v. Silcox, 6 Ind., 39; Burden vy. Mayor of Mobile, 21
Ala., 309; McElroy v. Goble, 6 Ohio st., 187; Jewett v. Whitney, 48 Mo.,
242; White v. Griffin, 4 Jones, (N. C.) L. R., 139; Fray v. Vouls, 1 Ellis
& E., 839; Fullmon v. Stearns, 30 Vt., 448-513; Owen v. O’Reilly, 20 Mo.,
603; Hagan v. Riley, 13 Gray, 515; McCarty v. Beach, 10 Cal., 461; Hunt
v. Donal, Dudley, 180; Cox v. Sprigg, 6 Md., 274; Murry v. Bishop, 24
Md., 310; 10 B. Mow. 330; State v. Runhardt, 31 Mo , 95; Smith v. Jefts,
44 N. H., 482; Dent v. Davidson, 52 Ill., 109; Linder v. Lake, 6 Iowa, 164,
Wilson v. Whititoke, 49 Pa. st., 114; Brown v. Price, F. C. B. N. S., 598;
Pollar v. Porter, 3 Gray, 312; Donohue v. Henry, F. E. D.S., N. Y., 162;
1 Duer., 363, 12 C. B. 770; Smelting Co. v. Tipping, H. H. L. C. 642;
Smith v. Shockera, L. R. I. C. P., 564; Smith v. Heuzar. 25 Tex., 205;
Noonan v. Isle, 22 Wis., 27; Mecklain v. Blake, 22 Wis., 495; 40 Meigs,
374; 15 Mo., 322; Field on law of dam., 679-682; 2 Story R. 661; Little v.
Staunbock, 63 N. C., 285; Copeland v. Copeland, 30 Me., 446; Stowell v.
Bennett, 34 Me., 422; Dye v. Mann, 10 Mich., 291; Collier v. Gamble, 10
Mo., 467; 48 Me., 462-3; 11 Gray, 438; Ledbetter v. Morris, 3 Jones, 543;
Conroy v. Flint, 5 Cal, 327; Selfridge v. Lithgow, 2 Mass , 874; Bowen
v. Emerson, 3 Mass , 150; Marzetti v. Williams, 1 Barn. & Adol., 415-541;
Weller v. Baker, 2 Wils., 422; Johnson v. Slear, 15, C B. N. S., 330; San-
ders v. Stuart, L. R., 1 C. P. D., 826; Prescott v. Trueman, 4 Mass., 927;
‘Leffingwell v. Elliott, 10 Pick., 204.
CHAPTER XXI.
WATERCOURSES.
THe Lanp Owner Has A RicGuT TO USE THE WATER THAT
PASSES THROUGH HIS LAND. CASE OF GOULD V. Boston. THE
LAW MAKES A DISTINCTION BETWEEN NATURAL AND ARTI-
FICIAL WANTS. STREAM BELOW THE SURFACE. THE SURFACE
WATER MAY BE PREVENTED FROM FLOWING ON LAND. Dam-
AGES. PROFITS SHOULD BE CONSIDERED.
343. The Right of a Land Owner to Use the Water on his Prem-
ises. A person owning land on a stream of water may lawful-
ly use the water thereof for husbandry, for mills, or other pur-
poses, whatever may be the effect upon the proprietors below.
But he should exercise great care and not retain the water un-
necessarily by damming it upor by diverting it from its original
channel. If he wishes to use it for the purpose of propelling a
mill or other machinery, and is compelled to elevate it by
means of a dam, his dam should be such as is adapted to the
size of the mill and the capacity of the stream and the quan-
tity of water that usually flows therein, and he must make a
reasonable use of the water. The question as to whether the
defendant made a reasonable use of the water is one that should
292 LAW OF DAMAGES.
be left to the jury to be determined by the custom of the coun-
try in cases where dams have been erected and maintained
upon similar streams.’ The right of the upper proprietor is
not susceptible of being definitely defined in all cases, but will
vary with the circumstances of cach particular case.’
344. Gould v. Boston. In the case of Gould y. Boston the
facts as shown by the evidence were about as follows: The
defendant’s mill was adapted and appropriated to the size, ca-
pacity and water of the stream, and caused no further disturb-
ance or interruption of the flow of the water to the plaintifi’s
mill than was necessary and unavoidable in its reasonable use
for the defendant’s mill, but without reference to the plaintiff's
necessities or demands for water in a period of extraordinary
drouth, as occasionally occurs in the stream when the water,
though sufficient to operate the plaintiff's mill, would be in-
sufficient to operate the defendant’s, and without any prescrip-
tion or prior right of the plaintiff as occupant of the older priv-
‘ilege. The defendants, in order to create the proper head and
supply of water for their mill, were compelled to shut their
gate occasionally during the working hours and thus interrupt
the flow of the water to the plaintiff’s mill in a material man-
ner, but with reasonable regard to the best interest and -ad-
vantage of the defendant as proprietor of their mill, and in
conformity to the general usage of mill owners, running mills
on this and other similar streams. The defendant in his con-
duct acted wholly irrespective of the plaintiff’s interest and of
his necessities or demands for water, and neither acknowledge
nor conform wholly or in part to any claim made by the plain-
tiff that a sufficient quantity of water should be left flowing to
operate the plaintifi’s mill. Held, that an action would not
' Springfield v. Harris, + Allen (Mass.) 494.
” Ellen v. Dunean, 21 Barb, 230.
WATERCOURSES. 293
lie As has already been said, a man owning a close on an’
ancient brook may lawfully use the water thereof for the pur-
pose of husbandry, as watering his cattle or irrigating his
close, and he may do this either by dipping the water from the
brook and pouring it upon the land or by making small sluces
for the same purposes, and’ if the owner of the close below is
injured he cannot recover damages.’
345. The law sometimes makes a Distinction between Artificial and
Natural Demands. The law sometimes draws a nice distinction
between man’s natural and artificial wants, and holds that
where both are demanding water from the same source, that
the natural demands must be preferred over the artificial. It
defines natural wants to be such as are absolutely necessary
to preserve life. That artificial wants are such only as supply
the comforts of life. “To quench thirst and for household pur-
poses water is absolutely indispensable. In civil life water
for cattle is necessary. These wants must be supplied, or both
man and beast will perish. The supply of man’s artificial wants
are not essential to his existence—he could live if water was not
employed in irrigating lands, or in propelling his machinery.
So of manufactures, they promote the prosperity and comforts
of mankind, but cannot be considered absolutely necessary. to
-his existence. An individual owning a spring on his. land,
from. which water flows in a current through his neighbor’s
land, would have a right to use’ the whole of it if necessary to
satisfy his natural wants. If he desires to use it for irrigation
or manufactures, and there be a lower proprietor to whom its
use is essential to supply hss natural wants, or for his stock,
he must use the water so as to leave enough for such lower
proprietor. When the stream is small and doesnot supply wa-
ter more than sufficient to answer the natural wants of the
5 Clinton v. Myers, 46 N. Y. 511.
+13 Gray 442; 2 Weston v. Alden, 8 Mass. 136.
294 LAW OF DAMAGES.
different proprietors living on it, none of the proprietors can
use the water for irrigation or manufactures.” °
346. No Rule as to How or When Water may be Used. The
law lays down no rule as to how or when water may be used, as
between different owners; it looks to the quantity used and not
the mode of using it.) When two steam mills or factories are
located on the same stream, the rule is that so far as the water
is used by being converted into steam, neither is entitled to its
exclusive use, it is to be divided between them as nearly as it
may be, according to the respective requirements. If each re-
quires the same quantity, but while the water is incapable of
being thus divided with mathematical exactness, if the juty
should find that the upper factory has used more than its rea-
sonable share, or has diverted the water, after using it, from its
natural channel, or so corrupted it as to deprive the lower pro-
prietor of its use to such a degree as to cause a material injury,
it would be ground for damages, ultimately for an injunction.'
347. Streams Below the Surface. The law makes a distinc-
tion between the title of streams above ground and subterra-
nean streams of water percolating, oozing or filtering through
the earth. The owner of the surface may dig down to and’
use all the water there found to his own purpose, at his will
and pleasure. And if in the exercise of this right he inter-
cepts or drains off the water collected from under the ground
springs into his neighbor's well, that no damages can be recov-
ered. It has been held that the owner of a farm may dig a
ditch to drain his land or open and work a quarry upon it,
* Evans v. Murriworth, 3 Scam , (IIl.) 496; Kaler v. Beamon, 49 Maine,
207.
1 Perkins v. Dorn, 1 Root, (Conn.) 535; Wadsworth v. Tillottson, 15
Conn., 366; Bliss v. Kennedy, 43 IIL, 67.
PUBLIC OFFICERS. 295
even if by so doing he intercepts one of the underground
sources of a spring on his neighbor's land, which supplies a
small stream of water flowing through the land of each, there-
by diminishes the supply of water to the injury of the adjoin-
ing proprietor, that no damages could be recovered.’ So if a
spring produced by percolation through the land above in the
use of land for mining is destroyed by the owner above, he is
not liable unless guilty of negligence or malice.» The owner
of land through which a stream of water runs, may obstruct the
natural channel and divert it into any portion of his land, if
the water is returned into the former channel before it passes
upon the land of another.
348. Surface Water may be Prevented from Flowing on Lands.
The owner of land may prevent surface water from flowing
upon his land by erecting barriers or changing the level of the
soil, or may alter its flow after it has come upon his land, al-
though it may thereby be caused to pass off in a different di-
rection and in larger quantitiesthan previously, to the injury
of adjoining lands.* The authorities are somewhat in conflict
as to what should be the measure of damages in an action for
flooding the plaintiff's land. In some States the rule is that
the jury are, in assessing the plaintiff’s damages, authorized to
consider the benefits to the plaintifi’s land, caused by the flow-
ing. But this doctrine has lately been modified, so that it may
now be said that the measure of damages is a sufficient amount
to compensate the plaintiff for all loss he has sustained by
reason of the wrongful act of the defendant. The jury should,
in assessing damages, take into consideration all the circum-
* Ellis v. Duncan, 21 Barb., 230.
495 Penn., 528; Holderman v. Burkhardt, 45 Penn., 514.
5 Norton v. Valentine, 14 Vt., 239.
6 Howksworth v. Thompson, 98 Mass., 77.
LAW OF DAMAGES. 296
stances surrounding the case, and award the plaintiff such
damages as will make him whole.
349. Profits to be Considered. And in case of injury to mills
and machinery propelled by water, evidence of the profits of
such machinery during the time of the interruption should be
considered by the jury as a basis on which to estimate the
plaintiff's damages. In other words, the plaintiff can recover
the value of the use of the mill or other machinery during the
time it necessarily remained-idle by reason of the defendant’s
acts, and the amount it was permanently diminished in value
by reason of the defendant’s acts. The rule is sometimes stated
in this way: “the difference between the price of the plaintiff's
premises before the injury happened and the value immediately
after the injury, taking into account only damages which have
resulted from the defendant’s act. If injury is occasioned to
personal property by reason of the overflow, then it should be
considered at its true value? When there is no evidence as to
the amount of damages, and the wrongful act is proved, the
court will assess nominal damages. Exemplary damages are
sometimes allowed against persons for maliciously stopping a
watercourse.’
350. The Injured Party must use reasonable means to Prevent
Loss. But in cases of this kind as well as all others, it is the
duty of the injured party to use reasonable care to protect him-
self from further injury and loss, and he can only recover such
damages as he could not by reasonable effort have avoided, to-
3 Field on law of dam , 507.
> 11 Barb., 368, Walrath v. Redfield. 18 N. Y., 457; 16 Q. B, 643; Chase
v. N. Y. Central Railway Co., 24 Barb., 273; 51 Barb., 94; Luther v. The
Wennet Corp., 9Cush., 171; Talbot v. Whipple, 7 Gray, 122; Watts v.
“T. G. R. C., 32 Lant, (N. 8.) Q. B., 279.
WATERCOURSES. : 297
gether with the reasonable expense and value of time spent
for such purpose. But he must act in good faith in
* Walker v. Butz, 1 Yates, (Pa.) 574); Summers v. Brown, 5 R. I , 299;
Brown v. Brown, 80 N. Y., 519; Elliott v. Fletcher, 10 Cush., 191; Bur-
den v. Mayor of Mobile, 21 Ala., 309; McElroy v. Goble, 6 Ohio st., 187;
‘Gillett v. Johnson, 30 Conn., 180; Wadsworth v. Smith, 11 Me., 278;
Earl v. Dutest, 12 N. Y. Eq., 280; Curtis v. Kiesler, 14 Barb., 511. Wil-
son v. Blackbird Creek Manf Co., 1 Peter, 245; Lewis v. Stein, 16 Ala.,
214; Howard v. Ingersoll, 17 Ala., 780; Eddy v. Simpson, 3 Col., 249;
Hill v. Newman, 5 Col., 445; Kelly v. Notono Water Co., 6 Col., 105; S.
P. Hoffman v. Stone, 6 Col., 46; Morris y. Beckwell, 7 Col., 261; Parke v.
Killham, 8 Col., 261; Thompson v. Lee, 8 Col, 275; Bear River auben
W.and M. Co. v. York Co., 8 Col., 327-336; White v. Todd’s Valley
Water Co., 8 Col., 443; Humphries v. McCall, 9 Col , 59; Weaver v. Con-
_gey, 10 Col. 233; Brown v. Smith, 10 Col. 508; Kemble v. Gilbert, 12 Col.
27; Weaver v. Eureka, &c., Co., 15 Col. -271; James v. Williams, 31 Col.
211; Davis v. Gale, 32 Col. 26; Wadsworth v. Tillotson, 15 Conn. 366; Per-
kins v. Dow, 1 Root (Conn.) 535; Bliss v. Kennedy, 48 Il. 67; Blanchard
v. Baker, 8 Me. 253; Dwinel v. Barnard, 28 Me. 554; Ganel v. Looney, 14
Allen 40; Labdell v. Simpson, 2 Nev. 274; Ophir Co. v. Carpenter, 4 Nev.
534; Buller v. Runnels, 2 N H. 255; Brakely v. Sharp, 10 N. Y. Eq. 206; _
Delhi v. Yeamans, 50 Barb. N. Y. 316; Morgan v. Mason, 20 Ohio 201;
Coen v. White, 8 Ohio st. 401; Mayor v. Commissioners, 7 Pa. st. 348;
Dalington v. Panter, 7 Pa. st. 473; McCord v. High, 24 Iowa 336; State v.
Glear, 7 Jones (N. C.) 321-512; Polly v. McCall, 37 Ala. 20; Cotton v. Po-
casset Manufacturing Co., 3 Met. (Mass.) 429; Smith v. Miller, 11 Gray
145; White v. Chapen, 97 Mass 101; Watkins v. Peck, 18 N. H. 360;
Campbell v. Smith, 8 N. J. L. 140; Smith v. Adams, 6 Paige (N. Y.) 435;
Haight v. Price, 21 N. Y. 241; Rogers v. Page, Bryant Vt. 169; Givanch
y. Burbank, 12 Allen 459; Mandeville v. Comstock, 9 Mich. 536; Jackson
v. Halstead, 5 Law (N. Y-.) 216; Hill v. Smith, 32 Col. 166; Carbert v.
Auburn Gas Light Co., 22 Barb. 297; Porter v. Burden, 38 Ala. 651; Ben-
nett v. Whitney, 15 Col. 35; Kidds v. Laird, 15 Col. 161; McKinney v.
Smith, 21 Col. 374; Notoma, &c., Co. v. McCoy, 23 Col. 490; Nevada Wa-
ter Co. v. Powell, 34 Col 109; Lewis v. Baldwin, 9 Conn. 291; Brown v.
Owens, 27 Conn. 84; Plumleigh v. Dawson, 6 IIl. 544; Mitchell v. Parke,
26 Ind. 354; Addison v. Hock, 2 Gill 221; Greenleaf v. Force, 18 Pick.
117; Newbol v. Iverson, 8 Cush. 595; Read v. Barker, 30 N. J. L. 378;
Shield’s Amdt., 4.N. J. Eq. 234; Amola v. Foot, 12 Wend. 330; Walls v.
Kinney, 23 Wend.. 484, Wilber v. Brown, 3 Denio 356; Smith v. Adams,
6 Paige 435; Billinger v. New York, &c.; R. R. Co., 23 N. Y. 42, Wheatly
y. Baugh, 25 Pa. st. 528; Haldeman v. Buckhart, 45 Pa. st. 514; Pettibone
v. Whitlock, 27 Vt. 267; Clatfield v. Wilson, 27 Vt. 670; Johnson v. Jor-
dan, 2 Me., ete, 234; Gorman v. Hargadon, 10 Ala. 106; Hawksworth v.
Thompson, 98 Mass. 77-428; Kauffman v. Gisner, 26 Pa. st. 407; Miller v.
298 LAW OF DAMAGES.
making his outlay of money to prevent further injury.
Louback, 47 Pa. st. 154; Allen v. McCorkly, 3 Head (Tenn ) 181; Mark vy.
Gault, 10 Wis. 513; Root v. Driscoll, 20 Conn. 533; Sedgwick on measure
of damages, p. 153 to 156; 1 Hilliard on Torts, p. 582 to 625; 1 Wash. on
real property, p. 63 to 72.
CHAPTER XXII.
LIGHT.
THE Common Law oF Enatanp. A RicHt on EasEMENT MAY
BE ACQUIRED TO USE ANOTHER’S LAND TO OBTAIN LIGHT. THE
RULE 1S NOT ALLOWED IN THIS COUNTRY. IN SOME OF THE
STATES IT Is ALLOWED UNDER CERTAIN CIRCUMSTANCES.
351. The Common Law of England. By the common law of
England, as declared by the English courts, light istconsidered
an essential part of a house, and the right to use another’s land
for the purpose of obtaining it may be acquired by prescrip-
tion or a long continued uninterrupted possession. But in this
country the rule of the common law as declared by the English
courts has not been adopted to any extent. When the ques-
tion was first presented for adjudication to the courts of this
country they followed the common law rule as laid down by
the English courts, but in more recent times the doctrine has
been repudiated by the great majority, if not by the courts of
all the States.’ '
1 Parker v. Edgerton, 19 Wend. 308; Keato v. Hugo, 115 Mass. 204; 15
Am. 80.
300 LAW OF DAMAGES.-
352. The Common Law Rule in this Country. In this coun-
try each individual freeholder is entitled to the uninterrupted
enjoyment of everything under or over his land, and no one
has the right to disturb him in the enjoyments of these rights.
But in every other direction the law confines him inside of the
bounds of his own premises. And if the owner of one tract of
land erects a house upon his premises with a window over-
looking his neighbor’s land, and his neighbor erects a house on
his land in such a manner as to destroy the light received
through that window, the owner of the house could not main-
tain an action for damages. And the fact that he had enjoyed
the benefit of the flow of light and air for a long continuous
length of time over his neighbor’s land would not give him a
right or easement over the premises that the law would recog-
nize. Therefore, implied grants and implied reservations,
based upon necessity or use alone, should not be applied to
easement for light and air over the premises of another in any
case.’
353. The Rule Adopted by Some of the States. The courts of
some of the States hold that an implied grant of an easement
of light will be sustained in case of real and obvious necessity,
and denied where the owner of the dominant estate can, at a
reasonable cost and expenditure, have or substitute light to his
building so that he may continue and have a reasonable enjoy-
ment of the same, leaving the owner of the servient estate also
to the enjoyment of his own property free from restriction that
would otherwise imposed upon it. In the application of this
> Parker v. Edgerton, 19 Wend. 308; Keato v. Hugo, 115 Mass. 2
Muller v. Stricker, 19 Ohio stat. 135; Maynard v. Esher, 17 Penn. st. 222;
Harverstick v. Sipe, 33 Penn. st. 868-371; Dodd v. Burchell, 1 H. & C. 112;
Myers v. Gimmel, 10 Barb 537, Palmer \. Wetmore, 2 Sanf. sup. C. R.
316; Collier v. Pierce, 7 Gray 18; Pierre v. Fernal, 26 Me 436; Napier v.
Bulwinkle, 5°"Rich. 311; Cherry v. Stein, 11 Md. 1; Hubbard v. Town, 33
Vt. 295; Ward v. Neal, 37 Ala. 500; Atkins v. Chilson, 7 Meet. 398.
4;
LIGHT. 301
principle some embarrassments will occasionally arise in deter-
mining the degree of necessity that ought to be required to
support the right to-the easement, and each case must neces-’
sarily be settled on the facts and circumstances surrounding it.
And after all this rule is not in opposition to the principles of
justice and equity.’ For the amount of damages see Nuisance.
5 Powell v. Smith, 5 W. Va. 1, 1 Saunders; Holmes v. Elliott, 2 Bing
76; Proctor v. Haggson, 29 Eng. Law & Eq. 453; Washburne* on ease—
ments, 586-7; 2 Hill on Torts, 1-8; 2 Washburne on real property,
316; Perry v. Fennal, 26 Maine 436; Glane v. Harding, 3 Huel. & Nor.
939; Fifty Association v. Tudor, 6 Gray 259-60; Rogers v. Swain, 10 Gray
376; Carriage v. Dee, 14 G@ray 583; Hubbard v. Town, 33 Vt. 295; Helstick
v. Sipice, 33 Pa 368; King v. Miller, + Halst. ch 559; Myers v. Gammel,
10 Barb. 537; Atkins v. Chilson, 7 Meet. 398; Irwin v Dixon, 9 How. 10;
Thompson v. Bowen, Sayes 216; Blunk v. McCormick, 3 Denio 283;
Washburne on easements,’ 492 to 497; Gaber v. Grabel, 16 Ill. 558; Hog-
son v. Jeffers, 52 Indiana 334; Morrison v. Magaith, 24 Iowa 35; Parke v.
Foot, 19 Wend. 309; Mullen v. Strickler, 19 Ohio st. 135. .
CHAPTER XXIII. .
DAMAGES FOR ENTICING AWAY A SERVANT.
354. Damages for Enticing Away a Servant. When the plain-
tiff has employed a servant for a definite time and he is
enticed away by the defendant and the plaintiff is injured
thereby, he may maintain an action to recover damages for
such injury. In such cases the plaintiff can generally re-
cover the value of the services lost up to the time of the trial.
And where he has lost the entire service, the recovery should
be for the whole time. In estimating the damages the jury
would not be authorized to take as a basis for calculation the
amount per day or month the plaintiff was paying his servant.
But it should take as a basis the value of the servant’s labor
to the plaintiff over and above the wages he was receiving.
The rule that the plaintiff can only recover such damages as
are the natural.and proximate consequence of the act com-
plained of, and cannot be allowed for remote and speculative
damages, such as poor crops occasioned by the loss of the ser-
vant’s labor, etc., applies.!
: Salters v. Howard, 43 George 601; 48 Penn, 320.
DAMAGES FOR ENTICING AWAY A SERVANT. 303
335. But where the servant is employed to work by the
piece, and is enticed away by the defendant, the plaintiff may
recover the loss he has sustained by reason of his servant fail-
ing tocomplete his work. But in this class of cases as well as
in most all others the damages will be either enhanced or re-
duced by the conduct of the parties or the surrounding cir-
cumstances. The plaintiff cannot, after his servant has been
induced to leave him, fold his arms and make no effort to sup-
ply his plaee, and recover damages for the value of the service
‘for the time that he had him employed. He must make use
all reasonable means to supply the loss, and if, after a proper
effort, he fails, he may then, but not until then, recover for the
loss of the whole time. The defendant, therefore, may show
in mitigation of damages that the plaintiff could, by reasona-
ble diligence, have piocured other labor that would have been
equal to and supplied the place of the servant abducted away.”
2 Hays v. Borders, 6 Ill. 46; Salter v. Howard, £3 Georgia 61; 48 Penn.
330.
CHAPTER XXIV.
MITIGATING CIRCUMSTANCES.
Mirigatinc Circumsrances. Tue AIM or THE LAw. EXeEn-
PLARY DAMAGES. LIBEL AND SLANDER. MAaLicIous PROSE-
CUTION. FALSE IMPRISONMENT. NEGLECT OF AN AGENT.
In TROVER. BREACH OF CONTRACT. CRIMINAL CONVERSA-
TION. SEDUCTION. BREACH OF PROMISE TO MARRY. THE
OLD RULE OF THE COMMON LAW WHICH MADE NO DIFFERENCE
BETWEEN A MALICIOUS ACT AND A MISTAKE, IS BEING MODI-
FIED.
356. The Aim of the Law. The law aims to measure the
damage by the offense and injury, and it is always proper for
the jury to inquire into all facts and circumstances surround-
ing the parties at the time of the commission of the injury
sued for, in order to arrive at a correct estimate of damages
sustained by the injured party. All the facts constituting the
resgesta should go to the jury.
357. Case of a Common Carrier. Thus in an action against
a common carrier for negligence in suffering goods to be dam-
aged by exposure to the weather, the defendant may show in
MITIGATING CIRCUMSTANCES. 305
mitigation of damages that the plaintiff received the goods in
their damaged condition.!
358. Personal Injury. The law in tenderness to human ,
frailties, distinguishes between an act done deliberately and an
act proceeding from a sudden heat. If, therefore, upon a sud-
den quarrel two persons fight, and one kills the other, this has
been adjudged only manslaughter. Soif a man be greatly
provoked, as by pulling his nose, or other great indignity, and
immediately kills the aggressor, though this is not excusable,
the offense is mitigated homicide. But in every case of homi-
cide upon provocation, if there be any time intervening be-
tween the insult and killing sufficient for passion to subside
and- reason to interpose, the offense becomes murder. In
analogy to this principle, evidence in civil action for an assault
and battery is admitted in mitigation of damages to show a
provocation on the part of the person complaining of the in-
jury, but the provocation must be so recent as to induce a fair
presumption that the violence done was committed during the
continuance of the feeling and passions excited by it before
the blood has time to cool. A different rule from this would
have a tendency to encourage breaches of the peace.? The
character of the attacking party, the circumstances that sur-
round the defendant, whether he was alone or surrounded by
persons who would aid him, whether his life or personal safety
were in peril, and the disposition of the persons present to-
wards him, whether they were friendly or unfriendly, can be
shown.’
1 Bowman vy. Teall, 32 Wend. 306; Ogden v. Marshall, 8 N. Y. 340.
2 Fullerton v. Warrick, 3 Black (Ind.) 219; Avery v. Ray, 1 Mass. 12;
Lee v. Woolsey, 19 Johns R. 319; Rochester v- Anderson, 1 Bibb 428.
3 Castner v. Sltker, 83 N. J. L. 507.
In the case of Lee v. Woolsey the defendant, offered to prove in miti-
gation of damages that in the month of February preceding the plaintiff
had addressed to the Secretary of the Navy a scandalous and defamatory
306 LAW OF DAMAGES.
359. Exemplary Damages. But it has been held that where
the plaintiff i in an action for an injury to his person claims
exemplary damages, that the defendant should not be confined
and restricted in proving matters which took place at the very
time of the injury complained of, but that he has a right to
show the true relation existing between him and the plaintiff
in order to enable the court or jury trying the cause to deter-
mine how far it was wanton, malicious, vindictive or unpro-
voked, or how far extenuated by the conduct, declaration or
provocation of the plaintiff. And where the plaintiff had, in
combination with another, made repeated attacks on the de-
fendant, the court held that proof that he had taken part in
the previous attacks, could be introduced in mitigation of
damages.*
360. Libel and Slander. In an action for libel or slander,
the defendant may show in mitigation of damages any fact
that has a tendency to disprove malice or bad motives. Thus,
he may show that at the time the words were uttered there
waa a general report in the plaintiff's neighborhood that he
had committed the crime charged.‘ And-in case of slander he
may show for the same purpose that the words were spoken in
the heat of passion or under excitement, or that the miscon-
duct of plaintiff gave rise to the charge and caused it to be be-
lieved. And in either libel or slander the defendant may,- in
letter respecting the defendant, charging him with having embezzled the
public property under his care as a post captain, and that the letter had
been circulated among the citizens of the place where the parties re-
sided, and had been known to the defendant only an hour or two. The
evidence was rejected. 19 Johns 319. °
® Prentiss v. Shaw, 56 Me. 427; Tryson v. Booth, 100 Mass. 258; Cast-
ner v. Sliker, 33 N. J. L. 507; Butt v. Gould, 34 Ind. 552; 2 Greenleaf, sec.
263; Marker v. Miller, 9 Md. 338; Anderson v. Johns, 3 Har. & J. 162;
Allis v. Nauson et al., 41 Ind. 154.
* Wetherbee v. Marsh, 20 N. H. 561; Walls v. Faser, 7 C. and P. 369;
Chil v. Homer, 13 Pick. 503.
MITIGATING CIRCUMSTANCES. 307
mitigation of damages, show that the plaintiffs reputation has
sustained no injury because he had no reputation to lose.®
361. And he can show in mitigation of damages that
prior to and at the time of uttering the words there was a
general suspicion and common report of the guilt of the plain-
tiff of the crime imputed to him by the defendant for which
the action was brought.
362. Malicious . Prosecution. Thus in case of a malicious
prosecution, the defendant may show in mitigation of dam-
ages all the suspicious circumstances going: to establish the
plaintiffs guilt. There is some conflict among the authori-
ties as to whether the defendant can attack the plaintiff's
5 Root v. King, 7 Cow. 618; Inman v. Foster, 8 Wend. 602; 1 Green-
leaf, sec. 55; Dewitt v. Greenfield, 5 How. 275; Eastland v. Cadwell, 2
Bibb 21; Calaway v. Middleton, 2 A. K. Marsh 372; Burnon v. Lyden, 1
Root 354; Austin v. Hanchett, 2 Root 148; Gales v. Meredith, 7 Ind. 440.
The proof of bad reputation of the plaintiff must be confined to the
time before the uttering of the language complained of. Townsend on
libel and slander, sec. 409.
« Field on damages, 114; 2 Stark on slander, 84 to 88; 2 Greenleaf on
evid., sec. 275; Hoct. v. Reed, 1 B. Mon. 166; Treat v. Browning, 4 Conn.
408; Walcott v. Hall, 6 Mass. 514; Alderman v. French, 1 Pick. 1; Mullett
v. Hulton, 4 Esp., 248; Bodwell v. Swan, 3 Pick , 376; Root v. King, 7
Cow., 618; Matson v. Buck, 5 Cow., 499; McAlexander v. Harris, 5
Mass , 465; Boice v. McAllister, 3 Fair, 310; Fuller vy. Dean, 31 Ala., 654;
Morris v. Baker, 4 Har., 520; Fletcher v. Burrows, 10 Ia., 557; Moyer v.
Pine, 4 Mich., 409; Bradly v. Gibson, 9 Ala., 406; Nelson v. Evans, 1
Deu., 9; Caloma v. Middletown, 2 A. K. Marshall, 372; Bevins v. Stokes,
27 Miss., 239; Weatherby v. Marsh, 29 N. H., 561; Case v. Marks, 20
Conn., 248; Budgeman v. Hopkins; 34 Vt. 532; Waithmon v. Weaver, 11
Price, 257; Night v. Foster, 39 N. H., 576; Wolcott v. Hall, 6 Mass., 514.
Alderman vy. French,1 Pickering, 1; Henson v. Veach, 1 Blackf., 369;
Woods v. Anderson, 5 BI., 598. The question whether the defendant
‘can give evidence of rumors as to the guilt of the plaintiff is not fully
settled. Townshend on L. &6&., 410.
The defendant may show when the words were uttered that his mind
was so besotted by intemperance, and his character so depraved that no
one who knew him would have regarded what he said. 7 Ind., 440.
308 LAW OF DAMAGES.
character for the purpose of reducing the amount of his recov-
ery. But it may now be considered pretty well settled by the
weight of authority in this country, that the plaintiff is en-
titled to damages for injury to his reputation, and that, there-
fore the value of that reputation is in issue and must be fixed
by the jury in making up their verdict, and that evidence is
admissible, not only to rebut the presumption of malice and
wantof probable cause, but also in mitigation of damages.
The English authorities-hold that the plaintiff cannot recover
damages for injury to his reputation, unless it is expressly
alledged in the complaint.
363. False Imprisonment. The defendant in case of false
imprisonment may show in mitigation of damages, every cir-
cumstances connected with the transaction that has a tendency
to show that he acted with honest motives and good faith in
making the arrest. So he may show that the plaintiff in-
sulted him with vile epithets and gross seditious language
that caused him to make the arrest. And he may show for
the same purpose that the plaintiff was strongly suspected and
accused by the public for the crime for which he wasarrested.’
364. Damages for Neglect of an Agent. The law imposes on
an agent who undertakes to collect a bill, the duty of present-
ing it for acceptance and payment without unnecessary delay,
and the fact that it was not put in his hands until some time -
after its date is no excuse for his neglect of this duty. When
under such circumstances the bill is not collected the agent is
prima facie liable for the whole amount thereof, with interest.
1 Israel v. Brooks, 23 Ill., 575; Martin v. Hardesty, 27 Ala., 450; Dow-
ny v. Burch, 2M.& K., 374; Goodrich v. Warner, 21 Conn., 432; Smith
v. Hyderman, 10 Cush, 554; see ant. sect. 184; 1 Addison on torts, 767;
Rodredz v. Todmin, 2.
2 Carpenter v. Packer, 23 Ia., 450; May on dam., 263; Field on law of
damages, 541.
MITIGATING CIRCUMSTANCES. 309
But he may show in mitigation of damages the actual loss
sustained. And also that the drawee of the bill would
not have accepted it had it been presented at the proper time,
and that the drawees credit at the time it should have been ac-
cepted was not good, etc.’
365. In Trover. In an action of trover or replevin, the
defendant may show in mitigation of damages, that the prop-
erty has been restored to the plaintiff. But if it becomes sub-
jected to a charge after the conversion or wrongful detention,
and before it was returned, such charge should be deducted
from the value when restored. If, as for example, the conversion
or wrongful taking or retention were of a watch, which the de-
fendant threw into a well, and the plaintiff hired a man to
descend into the welland get it, the expense of reclaiming it
should be deducted-from the value when returned. Or, if one
takes and wrongfully retains another’s horse, and leaves him
at an inn, and the owner reclaims him, the charge for his keep-
ing should be deducted from his value at the time the plaintiff
recovered him.®
And where property has been delivered, pending the suit,
only nominal damages can be given, unless for detention, inter-
est, or lien created, or charges made after the taking of the
property. A plaintiff who fails in a replevin suit, may show
in mitigation of damages, that the defendant’s only interest in
the property was by being under execution, which has been
satisfied.’ And the defendant may also show for the same pur-
2 Allen y. Suydam, 20 Wend.. 321; VanWert v. Walley, 5 Daniel &
Ryl., 374; Delaney v. Stoddat, 1 T. R. 188; Welister v. DeTastet, 7 T. R.,
757; Rundle v. Moore, Johnson cases, 36; Morris v. Summerville, 2
Wash., R., 203. Walloce v. tellfair, 2 T. R. 108.
; Greenfield Bankv. Leavitt, 17 Peck, 1; Tuck v. Moses, 58 Me., 461.
s Conroy v. Flint, 5 Cal., 327.
1 Hayden v. Anderson, 17 Ia., 158; Hawley v. Warner, 12 Ia., 42; Buck
y. Rhoads, 11 Ia., 348.
310 LAW OF DAMAGES.
‘
pose that the plaintiff is a mere bailee and has no interest in
the property except the right of a temporary possession.’
366. Contract. In case of a suit for a breach of contract,
the defendant may show in mitigation of damages that the
plaintiff could have, by a reasonable care and effort, prevented
the whole or any part of the injury resulting from his failure
to comply with the condition of hiscontract. The rule is that
if the injured party, through negligence or willfulness, allows
the damages to be unneccessarily enhanced the increased loss
justly falls upon him.’
367. Bad Spirit. And it may be laid down as a general
rule that in all actions where a bad spirit or malicious motives
enter into and form an element in the injury, and where they
may be inferred from acts and are considered in assessing the
plaintiff’s damages, or where they would furnish a basis for
assessment of exemplary, vindictive or punitory damages the
defendant may show in mitigation of the amount of recovery
that in the doing the act complained of he was not actuated by
a malicious motive.®
368. Criminal Conversation. In an action for criminal con-
versation and seduction of the plaintiff's wife the defendant
may show in mitigation of damages the previous bad character
‘of the wife for chastity, and he will not be confined to her gen-
eral reputation, but may show particular instances of unchas-
1 Bement v. Lockwood, 20 Wend., 223; Greenfield Bank v. Bennett, 17
Peck 1; 14 Peck, 356.
® Hamilton v. McPherson, 28 N. Y. 72; Miller v. Mariners’ Church, 7
Greenleaf 51; Shannon v. Comstock, 21 Wend. 461; Hecksher v. McCray,
24 Wend. 309; Clark vy. Massiglia, 1 Denio 317; Spencer v. Halstead, id.
606; Loker v. Damon, 17 Pick. 284.
* Johnson v. Jenks, 24 N. Y. 252; Thorn v. Knapp, 42 N.Y., 474,
MITIGATING CIRCUMSTANCES, 8311
tity—her letters to and her general deportment towards him-
self tending to prove that she made the first advancement,
But he will not be permitted to show the misconduct of the
wife subsequent to the alleged connection with him.’ And he
may show for the same purpose that after the husband had
discovered the adulterous conduct of his wife he still continued
to live and cohabit with her. And he may also show
for the same object that the plaintiff and his wife lived unhap-
pily together, that he treated her in a cruel, inhuman manner
and that such treatment was produced by drunkenness or
otherwise, and the plaintiff's bad character asa husband.* The
condition in life and pecuniary circumstances of the respective
parties may be shown as properly affecting the amount of
damages.’ That the wife had been guilty of adultery with
other men before with the defendant.?
369. Seduction. In an action by a parent for the seduction
of his daughter, the defendant may show in mitigation of
damages that the daughter prior to his alleged commerce with
her had had intercourse with other men.? And that the plain-
tiff was careless and indifferent in regard to his daughter, and
that he by his conduct afforded her opportunities for criminal
intercourse with men.’ And under a statute that authorizes a
female to sue for her own seduction, the plaintifi’s bad charac-
* Sanders v. Nelson, 4.N. H. 501; 2 Greenleaf evid., sec. 56; Hasler v.
Crill, 33 Barb. 283-4; Hodges v. Wendham, Peaks case 39; Gardner v.
Jadis, 1 Adm. N. P. 24; Palmer v. Cook, 7 Gray 418; Field on law of
dam., 563; Coleman v. White, 43 Ind. 429.
-5 Clause y. Clapper, 60 Ind. 548; Sanders v. Nelson, 4 N. H. 501; Big-
low’s leading cases on tort.
6 Norton v. Warner, 9 Conn. 172.
7 Rea v. Tucker, 51 Ill. 110; 1 id. 110, but see Case v. Marks, 20 Conn
248.
* Veny v. Watkins, 7 C. & P. 308.
2 Zerping v. Mouer, 2 Green. (Ia.) 520,
3 Threadgood v. Litogot, 22 Mich. 371.
312 LAW OF DAMAGES.
ter before the seduction may be shown in mitigation’ of
damages.‘ And he may show for the same purpose any fact
bearing on the relation of the person whose conduct is in ques-
tion and which fact constitutes a part of the res gest1.®
4
370, In a case of a breach of promise to marry, the
defendant may show in mitigation of damages all the
circumstances, such, for instance, as the limited time during
which the engagement has existed; that the plaintiff before
the promise to marry was made had an illegitimate child, if
unknown by the defendant ;? that she was wanting in virtue
and sobriety, and her dissolute conduct after the engagement
or before, if unknown to the defendant; that the “plaintiff
had connection with.other men before or after the promise,
and this, notwithstanding the engagement was formed, or con-
tinued after knowledge of the fact by the defendant, on the
ground that an unchaste woman cannot be injured by a
breach of a promise of marriage to the same extent as a vir-
tuous one.”
4 Smith v. Wilburn, 17 Ia. 30.
5 Threadgood v. Litogot, 21 Mich. 271.
3 Grant v. Wiley, 101 Mass. 189; Klofer v. Browne, 26 Wis. 372; Thorn
_ Vv. Knapp, 42 N. Y. 474; Bonlor v. Kelloge, 3 Mass. 189; Denslow v. Van-
horn, 16 Ia. 476; Johnson v. Calkins, 1 Johns case 116; Miller y. Stone, 7
Com. 22; Palmer v Andrews, 7 Wend. 143; Faulke v. Selway, 3 Esp. 236.
1 Burnett v. Simkins, 24 Ill, 264; Field on the law of damages, p. 120,
sec. 108.
On the trial of an action for a breach of marriage contract, where the
evidence did not tend to show any fraud in making the contract or in
its violation, the court instructed the jury as follows: “Ifthe marriage
contract and its breach by the defendant have been proved to your sat-
isfaction in this case, and if you further believe from the evidence in
the case that the elements of fraud mingles in this controversy as an in-
gredient in the act of the defendant, cither in making the marriage con-
tract with the plaintiff or its violation or breaking that contract, then
you may award to the plaintiff, in addition to the actual loss sustained
by her, such exemplary damages as shall tend to prevent a repetition of
MITIGATING CIRCUMSTANCES. 313
371. Good Faith. Theoldrules of the common law, estab-
tablished three or four hundred years ago, that made but little
or no discrimination in the assessment of damages between
those who acted willfully and those who acted through mis-
take, has gradually yielded to the force of Christian influences,
and is being modified in harmony with the rules of ethics and
the law of conscience, and now the defendant may show that
in doing the acts complained of he acted in good faith and in
the honest belief that he had the right to do what he did do.
Thus, it was held where the defendant in the exercise of what
he supposed to be legal authority, had cut down timber of the
value of twenty-five dollars and manufactured it into
hoops worth seven hundred dollars, that the plaintiff could
only recover the price of the timber in an action of trover.’
the injury and to punish the defendant.” Held, though the instruction
state a correct principle of law, yet under the evidence it was erroneous.
Dyden v. Knowles, 33 Ind. 148.
4 Wetherell v. Green, 22 Mich. 311; Foster vy. Wells, 41 Pa. st. 357;
Kerr v. Patterson, 41 Pa. stat. 357; Moody v. Whituey, 38 Me. 174; Chip-
man v. Hibbard, 6 Cal. 162; Whitebeck v. @ Y.Cent R. R. Co., 36 Barb.
644; Cox v. England, 65 Penn. 212; Young v. Lloyd, 65 Penn. st. 195.
.
CHAPTER XXV.
THE DUTIES OF THE PLAINTIFF.
Tue Duty or THE PLAINTIFF To Protect HimseLF. THE
PLAINTIFF MUST BE ACTIVE TO PREVENT Loss. AGREEMENT
TO FURNISH FRIGHT. ILLUSTRATION OF THE RULE. THE AP-
PLICATION OF THERULE IN CASE OF CONTRACT. CONTRACT TO
PERFORM JOB WORK. CONTRACT FOR SERVICE. THE GENER-
AL RULE. CASE OF TORT AGGRAVATE INJURY BY PLAINTIFF.
372. The Plaintiff Must be Active to Prevent Loss. As has al-
ready been said the law is no friend to those who make no ef-
fort to protect themselves, and where one has been injured by
the wrongful act of another the law requires him to use reason-
able diligence and means to prevent loss, and if he fails to do this
he can only recover such damages as he could not have, by the
use of reasonable diligence and care, prevented. And it may
be laid down as a general rule that where the plaintiff has
failed to use the proper diligence and care to prevent loss, he
will not be permitted to say that the loss that he might have
avoided by the use of the required means was the result of the
wrongful act of the defendant.'
| Douglas v. Stephens, 18 Mo. 362; Illinois C. R. R. Co. v. Fening,21 Ill
Ill. 646; Brooms Leg.Max., 279; Field on the law of dam., 181, sec. 126.
DUTY OF PLAINTIFF. 315
373. Thus, where the defendant agreed to furnish the
plaintiff with a boat load of corn to be carried at eighteen
cents per bushel to the city of New Orleans and failed to fulfill
his contract, the court held that it was the duty of the plaintiff
after he had ascertained that the defendant would not furnish
the corn, instead of lying idly by he should have employed
himself to as good advantage as he reasonably could for his
own gain and made the earliest and best disposition of his
boat to prevent loss. If he could not have got freight he might
perhaps have done something else to as good advantage, and if
his-boat could not have been used by him he should have pre-
served it with reasonable care, or sold it,as would have been
most judicious. And he could only recover such damages as
would make him reasonably whole at the time of the breach,
all the circumstances of the case being considered.
374, Illustration of the Rule. The rule can, perhaps,‘be as
well illustrated by supposing that a man has entered into a
contract to build a public work, which would occupy him ten
years and profit him a million of dollars. Just as he is ready
to commence operations he is notified that the contract must
be abandoned. He sues for damages for the breach of the.
agreement. Now, though he may be unable to obtain another
contract upon a public work, still shall he recover in the pend-
ing suit the million of money that he could have made had he
gone on and lived to complete the job he had contracted for
and have his time for ten years to be operating elsewhere?
That is, be as well off then as he possibly could have been at
the end of. ten years. We think not. He ought to recover
what would make him reasonably whole at the time of the
1 Jones, adm., v. Van Pattent, 3 Ind. 107; see Shannon v. McComstock,
21 Wend. ‘457; Skinner v Dayton, 19 Johns 513; Clark v. Marsella, 1
Denio 317.
316 LAW OF DAMAGES.
breach, all the circumstances of the case being considered.’
375. The Duty of a Party to a Contract to Protect Himself. “If
a party entitled to the benefit of a contract can protect him-
self from a loss arising from a breach at a trifling expense or
with reasonable exertion, he fails in social duty if he omits to
do so regardless of the increased amount of damages for which
he may intend to hold the other contracting party liable
Qui non prohibet cum prohibere possit jubet. And he who has it in
his power to prevent an injury to his neighbor and does not
exercise it, is often in a moral, if not in a legal view, accounta-
ble for it. The law will not permit him to throw a loss re-
sulting from damages to himself upon another, arising from
causes for which the latter may be responsible, which the
party sustaining the damages might by common prudence
have prevented. Foranexample,a party contracts for a quan-
tity of brick to build a house to be delivered at a given time,
and engages masons and carpenters to goon with the work.
The brick are not delivered. If other brick of equal quality
and for the stipulated price can be at once purchased on the
spot, it would be unreasonable by neglecting to make the pur-
chase to claim and receive of the delinquent party damages for
the workmen and the amount of rent which might be obtained
for the house if it had been built. The party who is not
chargeable with a violation of his contract should do the best
he can to prevent loss in such cases, and for any avoidable loss
occasioned by the failure of the other he is justly entitled to a
liberal and complete indemnity.’
376. Personal Contract to Perform Work. Where a person
* Jones v, Van Pattent, 3 Ind. 107; Shannon v, Comstock, 21 Wend.
457; Skinner y. Dayton, 19 John 318. :
8 Miller v. Mariner Church, 7 Greenleaf 51; see Hamilton ». McPher-
son, 28 N. Y. 72; Polk v. Daly, 4 Daly 411.
’
DUTY OF PLAINTIFF. 317
contracts to do a certain amount of work at a stipulated price
upon material to ve furnished by his employer within a speci-
fied time and is ready and willing to perform, but is prevented
by a failure of the employer to furnish material as promised,
he is entitled to merely compensatory damages, and where
during such time he is offered other employment of the same
kind, he is not entitled to the whole amount of profits he
would have made if the contract had been fully performed by
both parties.‘ .
377. .The Application of the Rule to Contracts for Service. The
rule that we are now considering applies in case of a breach of
contract to perform personal service, as where one is employed
at a stipulated price for a certain length of time and is dis-
charged before the expiration oftime and brings an action for
damages. In such case the employe cannot recover the full
amount pro rata of the unexpired term, provided he could have
found other suitable employnient elsewhere or, if after the dis-
missal, he was afterwards engaged in profitable business or em-
ployment. In either case whatever he might have earned or
has earned during the balance of the time, if less than the pro
rata, amount contracted to be paid by the defendant, should be
deducted from the stipulated amount. And ifit is shown that
the amount he might have earned by reasonable exertion or
the amount he earned exceeds the amount contracted to be
paid, there can be no recovery.’
378. The General Rule. The law for wise reasons imposes
4 Heauamlon v. Kramer, 31 Ind. 241; Dunn v. Johnson, 33 Ind. 54; 39
Ind. 373; Field on the law of damages, sec. 133; Hunt v. Crane, 4 George
(Miss.) 669; Costigan v. Mohawk & Hud. R. Co, 2 Denio 609.
5 Jones v. Van Pattent, 3 Ind. 107; Hunt v. Crane, 4 George (Mass.)
669; Costigan v. Mohawk & Hud. R. Co., 2 Denio 609; Polk v. Daily, 4
Daily 411; Shannon v. Comstock, 21 Wend. 460; Richards v. Edick, 17
Barb. 260; Bennett v. Smith, 15 Wend. 493; Dustin v. McAndrew, 44 N.
Y. 78; Costigan v. the M. & H. R. R. Co., 2 Denio 609.
318 LAW OF DAMAGES.
upon a party subject to injury from a breach of contract the
active duty of making reasonable exertion to render the injury
as light as possible. Public interest and sound morality ac-
cord with the law in demanding this, and if the injured party
through negligence or willfulness allows the damages to be
unnecessarily enhanced, the increased loss falls upon him, and
he can recover nothing for damages which, by reasonable dili-
gence on his part, could have been prevented.
379. Damages Where the Injury is Aggravated by the Plaintiff.
It is a general rule of law recognized both in England and this
country that the defendant is to be held responsible for all the
“losses that are the direct and natural consequence of his
wrong, such as by a wound inflicted, sickness, disability, and
expense incurred in consequence thereof. But where the con-
sequences have been aggravated by the gross neglect or the
want of ordinary care on the part of the plaintiff the defendant
is not responsible for such damages.’” “It is easy to imagine,”
says Justice Wadom, “Some trivial misconduct or slight neg-
lect which shall do no direct harm, but setting in motion
some second agent shall move a third, and so on until the
most disastrous consequences shall ensue. The wrong-doer
unfortunately, rather than seriously blamable, cannot be made
answerable for these consequences. He shall not answer for
those which the party aggrieved has contributed by his own
* Polk v. Daily, 4 Daily 411: Hamilton v. McPherson, 28 N. Y 76; Dus-
ton v. McAndrews, 43 N. Y. 237; Shannon vy. Comstock, 21 Wend. 460;
Richards v. Edick, 17 Barb. 260, and cases cited 265.
" Walker v. Ellis, 1 Sneed (Tenn.) 515; Davis v. Fish, 1 Green. (Ia.)
406; 3 Parson on contracts, 177; Darwin v. Potter, 5 Denio 306; Stover v.
Bleekill, 51 Me 439.
Suppose a man should enter his neighbor’s field unlawfully and leave
the gate open. If, before the owner knows it, cattle enter and destroy
the crop the trespasser is responsible, but if the owner sees the gate open
and passes it frequently and willfully or obstinately, or through gross
DUTY OF PLAINTIFF. 319
blamable negligence or wrong to produce, or for any which
such party by proper diligence might have prevented.”
negligence leaves it open all summer and cattle getin, it is his own folly.
So if one throws a stone and breaks a window the cost of repairing the
window is the ordinary measure of damages, but if the owner suffers the
window to remain without repairing a great length of time after notice
of the fact and his furniture or pictures or other valuable articles sustain
damage, or the rain beats and rots the window, the damage would be
remote We think the jury was rightly instructed that as the trespass
consisted in removing a few rods of fence, the proper measure of dam-
age was the costs of repairing it, and not the loss of the subsequent year’s
crop arising from the want of such fence.
Loker v. Damon, 17 Pick. 284; see Thomas v. Shattuck, 2 Met. 615; 3
Parson on contract, 177, 2 id. Flower v.-Adams, 2 Taunt 314: Miller v.
Marine Church Company, 7 Greenleaf 51; Hamilton v. McPherson, 28
N. Y. 72; Davis v. Fish, 1 Green (Ia.) 407; Chase v. the N. Y., &c, R. R.
Co., 24 Barb. 278; Hassa v. Junger, 15 Wis 598; Bridge v. Grand J. R.
Co., 3 M. & W. 244; Davis v. Mann, 10 M. & W. 546; Walker v. Ports, 2
Duer N. Y. 363.
’ Harrison v. Berkly, 1 Stable (S. C.) 548; Shearman & Redfield on
negligence, sec. 598; McGee v. ‘Stone, 53 Pa st. 436; Bennett v. Lock—
wood, 20, Wend. 223; Field on the law of damages, sec. 129.
CHAPTER XXVI.
DAMAGES ON CONTRACTS.
BreacH oF Promise. Common Law AcTION. WHAT THE
PLAINTIFF MUST PROVE. THE ELEMENTS OF DAMAGES, Ex-
EMPLARY DAMAGES. Cas oF SouTHARD Vv. RExFoRD. THE
GENERAL RULE AS TO EXEMPLARY DAMAGES. THE PROVINCE
OF THE JuRY. SEDucTION. MITIGATION OF DAMAGES. Mar-
TERS THAT CANNOT BE CONSIDERED AS A DEFENSE.
880. Action at Common Law. An action of assumpsit at
common law is the proper remedy for a breach of promise to
marry.!. And the rules of pleading in such cases are generous
and the time and place need not be alleged with great particu-
larity.” If, however,the time was fixdd (on a day certain)when
the marriage should take place, then it should be so alleged in
the plaintiff’s declaration or complaint.’ And if the defendant
was to marry the plaintiff on request, the complaint or declar-
ation should allege a request and refusal. And if there was
12 Saunders on plead and evidence, 663.
2 2 Chitty pleadings, 321.
5 See authorities above.
* See above authorities.
BREACH OF CONTRACT. 321
an agreement to marry and no time fixed when it should be
consummated, the law presumes that they were to marry in a
reasonable time, which should be alleged in the complaint.
And in all cases the declaration or complaint should show that
the defendant has failed or refused to fulfill his contract or to
marry the plaintiff, and that the plaintiff has ever since the
making of the contract held herself in readiness to marry the
defen dant.®
5 See 2 Chitty pleadings, 321. ;
Where one of the parties to a marriage to take place at a designated
time renounces the contract before that time has arrived, the other con-
tracting party may treat such renunciation as a breach of the contract
-and at once maintain an action. Hollawell v. Griffith, 32 Ia. 409; Burts
v. Thompson, 42 N. Y, 246; Frost v. Knight, Law Rep. 227, 19 Weekly
Rep. 77.
An agreement to marry until a breach is shown that terminates it,may
be regarded as a continuing contract by consent of the parties, and
hence in no just sense within the statute of fraud. Blackburn v. Mann,
85 Ill. 222; Short v. Stotts, 58 Ind. 29.
A promise of aman to marry when a divorce is decreed, is against
public policy and void. Noice v. Brown, 39 N. Y. L. 133.
The following is the usual form for the declaration at common law:
Section 2. Fora Failure to Marry on Request. After entitling, etc.:
“For that whereas heretofore, to-wit, on —— day of 18— the plaintiff
being then and there sole and unmarried, at the special instance and re-
quest of the said defendant, had then and there undertaken and faith-
fully~promised the said defendant to marry him, the said defendant,
when she, the said plaintiff, should be thereunto afterwards requested, ,
and he, the said defendant, undertook and then and there faithfully
promised the said plaintiff to marry her, the said plaintiff, when he, the
said defendant, should be thereunto afterwards requested. And the
said plaintiff avers that she, confiding in the same promise and under-
taking of the said defendant, hath always from thence hitherto remained
and continued and still is sole and unmarried and hath been for and
during the time aforesaid, and still is ready to marry him, the said de-
fendant And although the said plaintiff after making of the said
promise and undertaking of the said defendant, to-wit, &c., at &c., afore-
said, requested the said defendant to marry her, the said plaintiff; yet
the said defendant not regarding his said promise and undertaking, but
contriving and fraudulently intending, craftly and subtlely, to deceive
and injure the said plaintiff in this respect, did not nor would at the said
time when he was so requested as aforesaid or at any time before or af-
322 LAW OF DAMAGES.
381. What the Plaintiff must Prove in Order to Recover. After
the issues are closed, the plaintiff, in order to make out her
case, must show that she was, at the time of the making of the
contract, an unmarried woman, and that there was a mutual
terwards marry her, but said plaintiff, but hath hitherto wholly neglected
and refused to do so to her damage, &c.s
y Joun Suirn, Attorney for Plaintiff.”
3 2 Saunders’ pleading and evidence, 663; 2 Chitty pleadings, 321.
In most of the States the distinction between actions at law and suits
in equity and the form of all such actions as they formerly existed at
common law and in equity are abolished, and there is substituted in
their stead one form of action for the enforcement or protection of pri-
vate rights and the redress of private wrongs, which is denominated a
civil action.
The rules of pleading generally laid down by these statutes are these:
‘A statement of facts constituting the cause of action in a plain and
concise manner without repetition, and in such a manner that a man of
common understanding will know what is intended.” Under a statute
of this character the following form of complaint has been held good on
demurrer, after entitling the cause, etc.: ‘The plaintiff complains of
the defendant and says that the said defendant entered into a contract
with her in the month of June, 1867, by which it was agreed by and be—
tween them both that they would get married in the month of Septem-
ber following, and she avers that she made all necessary arrangements
and preparation to consummate said contract, and was ready and willing
at the time fixed aforesaid to fulfill the same, but she avers that the said
defendant wholly failed to fulfill his said contract to the great distress,
mortification and disgrace of the plaintiff, wherefore she demands judg-
ment for five thousand dollars.” Joun Smitu, Atty. for Plff.
2 Coles v. McKinney, 48 Ind.,
When the complaint alleged a mutual promise to marry, and averred
that the plalntiff, confiding in the defendant’s promise to marry, and his
representation that he was unmarried and competent to marry, contin-
ued, and still was, unmarried, and that she had, at the time no knowl-
edge, or information to lead her to believe that the promises and repre-
sentations of the defendant were false, and averred that the defendant
was, in fact,a married man. Held, that the complaint was sufficient
without alleging he knew the representation to be untrue. Blattmacher
v. Saal, 29 Barb., N. Y. 22; 7 Abb., 409. The allegation of a promise to
marry is generally supported by proof that he promised to marry on re-
quest or in a reasonable time, but is not supported by proof of a prom-
ise to marry on a specified future time, or on the happening of a future
event, &c. Clark vy, Pendleton 20 Conn., 495.
BREACH OF CONARACT. 323
promise or agreement between herself and the defendant to
marry.? And she may show this fact by circumstances from
which a jury may infer a mutual promise.’ The jury-may
infer a mutual promise from the conduct of the parties towards
each other. In the absence of direct evidence, the law always
raises a presumption that the. parties intend what their
conduct fairly indicates.‘ Hence, a jury may infer a promise
on the part of the defendant from such attention and respect
on his part as are usual in courtships, or in making matrimo-
nial engagements. The conversations and acts before the es-
trangement may be given in evidence for the same purpose.
The plaintiff may, for the purpose of showing a promise on her
part, show her apparent distress on learning that the defend-
* 2 Saunders on Pl. ev., p 664.
32 Saunders on Pl. & ev., p. 664; Potter v. Deboore, 1 Stark, 82.
Walters v. Bristol, 26 Conn., 398; Thurston v. Cownor, 8 Iowa, 185
Wigham v. Coots, 15 Mass., 1; Coil v. Wallace, 24.N. & L., 291; Hubbard
v. Bonstill, 16 Barb, 360; Perkins v. Henry,1 R.1I., 493. Murrion v.
Hastings, 12 Vt.. 345; Whitcomb v. Walcott, 21 Vt., 368.
When, in an action for a breach of promise of marriage, the date
when the promise was to be be fulfilled, &c., are laid under a vede lecit,
they need not be proved as laid, Prescot v. Guzler, 32 IIl., 312.
A jury is not authorized to infer a promise to marry on the part of the
defendant, from such attention and respect on his part, as is usual in
courtship or in making matrimonial engagements, nor that such a prom-
ise within the time limited by the statute for bringing an action in such
cases, even if such attention was continued up to within the time limit-
ed. 16B. Monroe (Ky) 284. The plaintiff may prove on the trial the
acts and conversation between herself and the defendant; their writ-
ten correspoiidence, and everything that took place between them be-
ore the estrangement, that would have a tendency to establish the alle-
gations of her complaint. Roy v. Smith, 9 Gray, 141; Hoit v. Molton,
21'N. H. 586; Conaway v. Shelton, 3 Ind., 334;Hay v. Graham, 8 Watts &
S. (Pa.) 27; Balda v. Stratton, 11 Pa. st., 316; King v. King, 2 Ind., 402;
Ellis vy. Guggenheimer, 20 Pa. st., 287. Lickey v. Blosser, 24 Pa. st. 401;
Moores v. Graves, 2 Ind., 354; Simmons v. Simmons, 8 Mich., 318;
Green v. Spencer, -3 Mo, 285.
5 Burham v. Cornell, 16 B. Monroe (Ky.) 284; Ray v. Smith, 9 Gray, |
141; King v. King, 2 Ind, 402; 2 Saunders Pl. & evid , 664; Wilds v.
Bogan, 47 Ind., 453.
324 LAW OF DAMAGES.
ant would not marry her, or was married to another, and also
her declarations made-to her sister or other near relative while
the defendant was visiting her as a suitor, and before the es-
trangement, that she was engaged to be married to him.’ But
such declarations are never received to prove a promise upon
the part of the defendant.’ And whatever the circumstances
may be which are relied upon to show a promise on the part
of the plaintiff they must be such as are sufficient to establish
the fact of a promise on her part to marry the defendant. And
as has already been said, the engagement or contract must be
mutual in order to be binding on the part of either. For
there is no other consideration for the promise of one than the
promise of the other. Hence the contract on the part of the
plaintiff must be such and must be so established that the de-
fendant could maintain an action thereon in the event that
the plaintiff had failed to perform it on her part.1 The dec-
laration and acts of the plaintiff that are so equivocal that
they may mean one thing as well as another should not be
allowed to go to the jury as tending to show a promise.”
385. The Elements of Damages. The elements that go to
make up, the damages, and which should be considered by
the jury, may be summarized as follows: 1. Her expense in
preparing for the marriage. 2. The disappointment of her
reasonable expectations. 3. The money value of the worldly
advantage of the marriage, which would give her a permanent
home, and the nature and character of that home. 4. Her
wounded affections. 6., Her pain, mortification, and distress
oa
° King v. King, 2 Ind., 402; Cates v. McKinney, 48 Ind., 562; Lukey v.
Bloser, 24 Pa. st., 401.
" Cates v. McKinney, 48 Ind., 562.
Cates v. McKinney, 48 Ind., 562.
> Weaver v. Bockert, 2 Penn. st., 80; Cates v. McKinney, 48 Ind., 562.
‘
BREACH OF CONTRACT. 325
of mind on account of her sore disappointment.’ The plaintiff
should recover in all cases such damages as would place her in
as good pecuniary condition as she would have been if the de-
fendant had fulfilled his contract, and hence the plaintift may
always show the pecuniary ability of the defendant,’ “as well
as injuries sustained from anguish of mind, blighted affection,
disappointed hopes, and injury to the character directly result-
ing from the breach.’”*
383. Exemplary Damages. The question whether exem-
plary damages may be allowed in this class of cases has been a
source of much controversy among the members of the legal
profession for centuries. But it may now be considered pretty
generally settled that if the element of fraud enter into the
act of the defendant, either in the making of the contract or in
its breach, exemplary damages may be allowed.?, And where
6 Johnson v. Jenks, 24 N. Y., 252; Sedgwick on damages, p. 248; ib.
455; Buy v. Dontz, 1 L. R. OC. 31.
7 Laurence v. Cook, 36 Me., 185; Sprague v. Craig, 51 IIl., 288.
’ Field on dam. p. 480, sec. 535. \ ;
2 Field on dam.. sec. 538; Draydon v. Knowles; 33 Ind., 148; Thorn v.
“Knapp, supra, Denslow v. Van Horn, 16 Ia., 476; Southern v, Rexford,
6 Cow., 254. In an action for breach of promise, the fact that the de-
fendant has set up and attempted to prove the plaintiff’s bad character,
should not be considered by the jury as a circnmstance to aggravate
damages, if such defense was pleaded in good faith, and with a reasona-
ble expectation of establishing it. D(nslow v. Van Horn, 16 Iowa, 476;
White v. Thomas, 12 Ohio, 312. In such a case the plaintiff is entitled
to show circumstances of contumely and aggravation attending a breach
of promise in order to enhance the damages, Chesby v. Chesby, 10 N.
H., 327; Greenleaf v. McCobb, 14 N. H. 303; Balay v. Stratton, 11 Pa. st.
316; Perkins v. Henry, 1 R.J., 493. Unchaste conduct on the part of
the plaintiff in an action of breach of promise to marry may be consid-
ered in mitigation of damages, although it was known to the defendant
at the time he made the promise. Denslow v. Van Horn, 16 Iowa, 476.
The defendant cannot give in evidence of general reputation that an-
other had supplanted the affection of the plaintiff; Willard v. Stone,
7 Cord, N. Y., 22. On drunkenness, see Butler v. McCauley, 38 Barb.
N. Y., 413.
326 LAW OF DAMAGES. x
the defendant in his answer attempts to justify his breach of
promise of marriage by stating therein, and thus placing upon
the record as a cause of his desertion of the plaintiff that she
has had criminal intercourse with various persons, and fajls to
prove it, the jury have aright to take this circumstances in
aggravation of damages.”
384. The Case of Southard v. Reaford. In the case of South-
ard y. Rexford, the plaintiff brought suit for a breach of prom-
ise of marriage. The defendant, with the general issue gave
notice that he would prove in his defense that the plaintift
had at various times and with various persons—specifying
them—committed fornication, after the alleged promise. He
attempted at the trial to prove this branch of his defense, but
failed. “On the question of damages, the Judge charged that
in a case of this kind the damages are always at the discretion
of the jury, and in fixing the amount, they have a right to
take into consideration the nature of the defense setup by the
defendant; that in his defense he had attempted to excuse his
abandonment of the plaintiff on the ground that she was un-
chaste and had committed fornication with different individ-
uals. But it appeared from the testimony of his own witnees
that her character in that respect had not been tarnished even
by the breath of suspicion; that with such a defense on the
record, a verdict for nominal or trifling damages might be
worse for her reputation than a general verdict for the defend-
ant; that if the defendant had won her affections and prom-
ised her marrige, and had not only deserted her without cause
but had also spread this defense upon the record for the pur-
pose of destroying her character, the jury would be justified
in giving exemplary damages.*
«
2 Thorn v. Knapp, 42 N. Y., 474; Southard v. Rexford, 6 Cow., 254;
Knifford vy. McConnell, 30 N. Y.,; 286; Davis v. Slagle, 27 Mo., 60.
*6 Cow. N. Y., 254; Parsons on contract, 551.
- BREACH OF CONTRNOT. 827
885. The General Rule as to Exemplary Damages. And it may
be laid down as a general rule that where the defendant at-
tempts dishonestly to injure the plaintiff’s reputation by alle-
gatioas made under pretense of justification or excuse for his
own acts, exemplary damages may be allowed. But it must
appear that the defense so set up was wanton and without any
reasonable belief or expectation that it could be established on
the trial.®
386. A Full Defense. The defendant may defeat the ac-
tion: 1. By showing that he never made the promise or
agreement. 2. That subsequent to the making of the marriage
contract plaintiff committed fornication.’ 3. That at the time
the contract was made he was an infant and not capable of
contracting. 4. That the marriageis prohibited by the law
of the State”? 5. That the plaintiff, prior to the time the mar-
riage was totake place used false and injurious language concern-
ing him. 6. That his health is such as to incapacitate him
from marriage, or render it unsafe or improper.’ But a pleaof
bad health by the defendant, subsequent to the promise has
been held bad.? But entire deafness or blindness, or other im-
5 Simpson v. Black, Black, 21 Wis., 206.
6 2 Irving v. Greenwood, 1 C. & P., 350; Field on the law of damages,
432; Dinslow v. Van Horn, 16 Ia., 476. :
7 Denslow v. Van Horn, supra; Simpson v. Black, supra; Kniffin v.
McConnel, 30 N. Y., 285; Davis v. Slagle, 27 Mo., 600; Field v. McKin-
ley, 21 Ill, 315. ‘ f
1 Hunt v. Peak, 5 Conn., 475; 1 Parsons on cont , 329.
2 2 Parsons on cont., 64; Harrison v. Caze 1Ld. Rogers, 387.
In an action for breach of promise to marry it is a full defense for the
defendant to show that he has bona fidely offered to marry the plaintiff,
and this too when the conduct of the defendant had been such as would
lead the plaintiff to believe that he never intended to marry her. If the
offer was made before she signified her intention to terminate the en-
gagement. Kelly v- Renfro, 9 Ala., 325.
1:Leeds v. Cook, 4 Esp., 256.
. 2 Atchison v. Baker, Peake Ad. Case 103-124.
3 Hall v. Wright, 96 Eng. C. L., 645.
828 LAW OF DAMAGES.
portant physical incapacity accruing after the promise should be
a good defense.! 7. That there was a dissolution of the con-
tract by common consent, but it must be shown tobe a real
and honest consent. An offer to renew or execute the contract
after the refusal is no defense, nor is change of feeling, nor the
fact that another has supplanted the plaintiff in the affections
of the defendant.’
387. The Damages at the Discretion of the Jury. The dam-
ages are peculiarly within the power of the jury in cases of
this kind, and courts both of England and this country are
very unwilling to grant a new trial on ‘account of excessive
damages.’
4 Short v. Stone, 8 Q. B., 369.
5 Southard v. Rexford, 6 Cow., 264; Kelly v. Renfro, 9 Ala , 326.
72 Parsons on contract, 67.
It is no defense of a breach of promise to marry, if the plaintiff at the
time of the promise was engaged to marry another person. Roper v.
Clay, 18 Mo., 888. When the declaration avers that the defendant has
married another, it is not necessary to aver in the complaint a request
and refusal. King v. King, 2 Ind., 402; Clements v. Moore, 11 Ala., 35.
A declaration in case of a breach of promise to marry should allege that
the plaintiff was ready and willing to marry the defendant, but that she
had failed or had offered to perform the contract on her part, and that
the defendant refused to comply. Feble v. Caplinger, 13 B. Monroe, 464;
Roper v. Clay, 18 Mo., 383; Grant v.Durgin, 45 N. H., 167.
1 Smith v. Woodfine, 1 C. & B. (N. S.) 660.
GrneraL Notses.—A single woman to whom a married man represents
that he is single and promises marriage may maintain her action against
him for a breach of promise. Blathmather v. Saal, 29 Barb (N. Y.) 22.
7 Able Prat. 400. If a man has been paying his address to one that he
supposes a modest person, and afterwards discovers that she is loose
and immodest, he is justified in breaking any promisc of marriage he
may have made to her, but to entitle a defendant to a verdict on that
ground the fact that she was a loose, immodest woman must be estab-
lished, and that he broke his promise on that account. Espy v. Jones,
1 Ala., 454; Wood v. Bellamy, 2 Root, (Conn.) 354; Butler v. Esplemer,
18 Ill., 44; Bell v. Eaton, 28 Ind.,.468; Denslow v. Van Horn, 16 Iowa,
476; Speman y. Wardwell, 32 Me. , 275 Perry v. Breakman, 44 Me., 164;
Goodale vy. Thurman, 1 Head. (Tenn, ) 209.
BREACH OF CONTRACT. 829
388. The Question of Seduction. The question as to whether
the plaintiff may introduce evidence of her own seduction to
enhance the damages, has been much controverted, and the au-
thorities are very much at variance upon the question. The
common law rule is that the plaintiff may show her own se-
duction for such purpose.’ But at common law a woman could
not sue for her own seduction, and as the statutes of many of
the States*‘authorize her to bring an action for her own seduc-
tion, the common law rule in those States has been abrogated
or modified by expressed legislation. And it may be laid down
as a rule in the States having such civil codes that such dam-
ages can only be allowed when the fact of her seduction is al-
leged in her complaint Where this is done it will bear an-
other action for the same injury. Seduction under a promise
of marriage is, in the eyes of the law viewed as special dam-
ages, and in order fora party tu recover for such injury it
must be alleged in the complaint® Because it is a rule of
pleading that whenever the damages sustained have not nec-
essarily accrued from the act’ complained of, and consequently
are not implied by law, then, in order to prevent surprise on
the defendant, the plaintiff must state the particular damages
she has sustained, or she will not be permitted to give evi-
dence of it.’ -
3 Walen v. Lamon, 2 Blackf. (Ind.) 191; 2 Stock. En. 942, note 1; Paul
v. Frazer, 3 Mass., 71; Boynton v. Kellogg, 3 Mass., 189; Burke v. Strain,
2 Bible, 341; Fidler v. McKinly, 21 Ill., 308; Espy v. Jones, 1 Ala., seld
case, 464; Tubhs v. Vandeek, 12 Ill , 446; Kenffen v. Connell, 30 N. Y.,
285; Wells v. Paget, 24 Pa. st R. 404, Sherman v Rawson, 102 Mass.,
395; Sawer v. Seulenberg. 23 Md., 288; Cow v. Wilson, 2 Overton, 233;
Coil v. Wallace, 4 Zab., 291; Kelly v. Riley, 106 Mass., 339.
* Wiles v. Bogan, 57 Ind., 453; Cates v. McKinney, 48 Ind., 562; Lind-
ly v. Dempsey, 44 Ind., 246.
5 Cates v. McKinney, 48 Ind., 562; Lindly v. Dempsey, 45 Ind., 246; 2
Parsons on contract, 70.
6 Olmstead v. Burk, 25 Ill., 86; Lindly v. Dempsey, 45 Ind., 246; Arm-
strong v. Piercy, 5 Wend., 535; Furlong v. Pollys, 30 Maine, 491; Taylor
v. Maguire 18 Mo, 517; Lentz v. Chotou, 42 Pa. st., 489; Fleming v.
Beck, 48 Pa. st. R. 309.
330 LAW OF DAMAGES. ;
389. Mitigation. The defendant may show in mitigation
of damages that the plaintiff is given to bad habits, such as
being an excessive drinker of intoxicating liquors and there-
fore not a fit or desirable companion and help meet in the race
of life! “But he cannot show in mitigation of damages that
since the commencement of the action the plaintiff has made
declaration to the effect that she had no affection for him, and
could not think of marrying him but for his property.’
The fact that the plaintiff, at the time of making the
marriage contract, was a lewd woman is no defense in an ac-
tion for a breach of it, if the defendant was aware of that fact
at the time he agreed to marry the plaintiff. But general
lewdness or lascivious conduct, even where known to the de-
fendant at the time he made the contract, may be shown in
mitigation of damages.*
390. Matters that Cannot be Considered as a Defense. As has
already been said the plaintiff is not precluded from recover-
ing damages if the defendant, at the time he made the promise,
knew that she was a loose or immodest woman, or if she pros-
tituted her person with the defendant’s connivance. Nor will
the fact that the plaintiff, prior to making the engagement
had been delivered of a bastard child, if known to the defend-
ant at the time he made the promise, bar an action for a
breach of it.*
) Burton v. McCauley, 1 Abb (N. Y.) 282.
? Miller v. Hays, 34 Ia., 496.
* Denslow‘’v. Van Horn, 16 Ia., 275.
* Birch v. Merrick, 1 Cor. & Ks., 463; Erwin v.Greenwood, 1 C. & P.,
350; Woodman vy. Bellamy, 2 Root, (Conn) 354; 2 Saunders P. & E., 347;
Parsons on Con., 550; Chitty on Con., 538; Morgan v. Yasborough, 5 L.
An. 316; 24 IIl., 264.
CHAPTER XXVII.
COVENANT OF WARRANTY.
Common Law oF THIs CountRY. FEuDAL TENURE. RIGHT oF
THE VASSAL. CONFUSED RULE. OVERTHROW OF THE FEUDAL
SYSTEM. BREACH UF DIFFERENT COVENANTS. Duty oF THE
GRANTEES. DAMAGES. CONSIDERATION OF THE QUESTION., OB-
JECTION TO THE GENERAL RULE. THE TWO RULES. THE
REASON FOR BOTH. DAMAGES WHERE PART OF A TRACT IS
TAKEN. THE RIGHT OF THE PLAINTIFF TO RECOVER INTER-
EST. REASON FOR THE SAME. RULE OF FULL COMPENSATION
APPLIES. AFTER ACQUIRED, TITLE ENURES TO THE GRANT-
EE. THE Britiso AND AMERICAN RULES. COVENANT FOR
A GOOD RIGHT TO CONVEY. DAMAGES UNDER: COVENANT
AGAINSI INCUMBRANCE. DAMAGES UNDER. QUIET’ ENJOY-
MENT. DAMAGES UNDER. COVENANT OF WARRANTY. Dam-
AGES UNDER.
891. The Common Law of this Country. The American
common law relating to real property is the outgrowth of the
feudal system that existed in England several hundred years
ago. And inorder to clearly understand the terms in daily
use in treating of the sale and transfer of real property and
332 LAW OF DAMAGES.
the right and duties of vendor and purchase, we must go back
and examine into some of the characteristics of that system.
The student should remember that prior to the introduction of ,
the feudal system into England all lands were held in allodi-
um or in fee simple, nulli sirvetuti obnoxium. But from the un-
settled condition of Europe during the tenth and eleventh
centuries, most of allodial estates were voluntarily changed
into a tenure or feudal estate by their proprietors for the pur-
pose of obtaining the protection of some neighboring lord or
chief by becoming his vassal. The theory of this system was
that all the land of any country belonged originally to the
king or chief who held dominion and ruled over it. And that
it was by him parceled out to others who were permitted to
hold them on condition subsequent that they should perform
certain duties and services for the superior who in theory re-
tained the property in the land itself‘ The donee, by this ar-
rangement, was said to hold of or under his superior; the one
taking the name of lord and the other vassal, and the right
to hold was called sizin.5
392. The Right of the Vassal. The right that the vassal
acquired to hold his land, having been granted to him as a
gratuity at first took the name of benefice, and was so desig-
nated by the early writers. But the common name was the
“feud, feod, fief or fee.” This holding of land under another
was called a tenure. The act by which the vassal was inducted
into and admitted to the right of possession and right of en-
joyment was called an investure.6 The condition on which
the vassal held the premises was that he must perform some
act or render some service to his lord for the privilege of hold-
ing possession of the land, which were called the services of
‘Spencer, Dg. Jus., 34-135; Law Mag., 605; 2 Black com., 53.
® Spencer, Eg. Jur., 185; 1 Washburn on real prop., 20-22.
* Wright on Tenure, 37.
COVENANT OF WARRANTY. 333
his tenure. These services could be varied at the will of the
lord. The lord was bound to protect the vassal, and the vas-
sal was sworn to uphold and protect his lord, and without the
oath of fealty no feud could subsist.®
392. The Feudal Grant was Hereditary. The feudal grant
Was an hereditary one. The vassal was also required to do
homage to the lord, which consisted in kneeling in the pres-
ence of other vasaals and declaring in a certain formula that
he became his homo, or man. The lord was under strong ob-
ligations to the vassal to protect him in the énjoyment of his
feud, and if he was unable to do this, then he had to supply
‘him with a new one of equal value. This was the origin of
the doctrine of warranty.7. And upon this doctrine is based
the rule in the assment of damages in a breach of covenant _
of warranty, which gives the vendee anamount equal to what
he paid out, with a specified per cent. for the use of it, where
he got no title.’
393. The Confused Rule in this Country. Owing to the pecu-
liar character of the structure of our government, it being
composed of many States, holding limited sovereign power,
with full authority to enact laws governing the sale and trans-
fer of real property, and the further fact that most of these
States have municipal laws bearing upon the subject, the
question of the measure of damages in case of a breach of any
agreement relating thereto, becomes very complicated and
hard to understand. As has already been said, the doctrine of
covenant of warranty had its origin in the feudal system.
6 Wright on Tenure, 35; 1 Wash. on real prop., 22. -
7 Wright on Ten., 5, 27; same, 38; 2 2 Black., 57; 1 Washburn on real
prop., 22. /
11 Flureau v. Thornhill, 2 W. Bl., 1078; same, Sedgwick leading cases
on measure of damages, 3.
334 LAW OF DAMAGES.
The lord was bound to recompense his vassal, on eviction,
with other lands to the value of the feud at the time of the
eviction. Fudum restuat ejusdem estimationis quod erat tempore ret
judicatia.* ,
394. The Feudal System Overturned. The overthrow of the
feudal system; and the compilation of the rules of common
law in reference to the sale and transfer of real property, the
covenant of warranty was brought into use. A deed, with
full covenant of warranty contains the following covenant
on the part of the grantor:
1. That he (the grantor) is lawfully seized.
2. That he hasa good right to convey.
8. That the land conveyed is free from all incumbrance.
4, That the grantee shall quietly enjoy the same.
5. That the grantor will warrant and defend the title
against all claims.’
a
395. The Common Law of the United States. The common
law of England, and the British statutes made in aid thereof,
were brought by our ancestors to this country, and so much
thereof as was suited to the condition of the people like that
of the early settlers were adopted as our common law. They
brought it with them as they did their language and regarded
it as a heritage of inestimable value, by which their rights of
? Flureau v. Thornhill, 2 W. & BI., 1078.
* Rawle on Covenant of Title, p. 43; Humphries on Real Proper-
ty, 126.
COVENANT OF WARRANTY. oe
person and property were to be regulated and secured.t Es-
pecially was this true in regard to the law of real property.®
396. Breaches of the Different Covenants. It may be laid
down as a general rule that the grantee cannot recover sub-
stantial damages for a breach of any of the covenants we have
just mentioned, until he has sustained actual injury. Sup-
pose, for illustration, that at the time of the conveyance, with
full covenant of warrant, the grantor was not lawfully seized,
or the premises not free from incumbrance, there would be a
breach of covenants at the time of the conveyance, but if the
grantee has been placed in possession, and enjoys actual pos-
session, or where he has not removed or paid off the incum-
brance, can only recover nominal damages until injured by an
ouster,” and so with all the other covenants, nominal damages
can only be recovered, until actual ouster or eviction by para-
mount title.’
We will now consider the measure of clamages on a breach
of these covenants:
397. Tne Duty of the Grantee. Before the grantee can
bring an action against the grantor for a breach of a general
covenant of warranty of title, there must have been some
hostile assertion of a paramount title to which he yielded, or
which was brought in by him. That he shall have been sued:
is not necessary, but it is essential that the true owner shall
4 Wharton v. Peters, 8 Pet. (U. S.) 659; Paulet v. Clark, 9.Cranch (U.
S.) 292; Patterson v. Win, 5 Peter (U. 8S.) 241; 1 Kent com., 333-473.
5 Seekitt v. Sacitt. 8 Peck, 315-318; Marshall v. Tiske, 6 Mass. 31;
Commonwealth v. Knowlton, 2 Mass., 535; Washburn on real proper-
ty, 17.
1 Field on law of dam., sect. 442; Green v. ‘Tig 54 Miss , 450; Kan-
sas Pacific R. R. Co. v. Dunnyse, 19 Kas., 539.
336 LAW OF DAMAGES.
have given notice in some way of his intention to assert his
claim. He cannot, merely because he has ascertained that
some other person holds a title superior to his own, abandon
that possession which he received from the grantor, and de-
mand areturn of the purchase money because the holder of
the paramount title may never claim or demand possession of
him, and the flow of time may have so ripened his possession
and title that he can successfully combat any hostile claim
that may be brought against him.’
398. The Consideration of the’ Question. There are but few
if any subjects, in the law that has given rise to more discus-
sion in this country than the question of the measure of dam-
ages for a breach of covenant of warranty. And this is owing
to the fact that land is constantly changing hands and the
value of land continually varying. But the rule for the assess-
ment of damages on a breach of covenant for quiet enjoyment,
and of warranty has been regulated by different States. But
in respects to the covenant of seizen and good right to convey
the rule as established in a few early cases has been consist-
ently followed, and it may now be considered a settled rule
that where the grantee has taken possession, and there has
? Green v. Irving, 54 Miss.; 450; Kansas Pacific Ky. Co. v. Dunmeyer,
19 Kansas, 539. Held, that the sale of wild land by the State is such a
hostile assertion thereof, that a person in possession under a defective
title can abandon possession, as upon eviction, and maintain his action.
Pacific R. R. Co. v. Dunnyre, supra.
The discharge of an incumbrance subsisting at the time of the con-
conveyance, and capable of being enforced, operates as an eviction pro-
tanto and a breach of general warranty of title, and an action may be
brought by the orginal or subsequent vendee, who discharges such in-
cumbrance. King v. Nortou, 10 Husk. (Tenn.) 384. A covenant of
warranty cannot be broken until there is an eviction or something
equivalent to an eviction. Bostwick v. Williams, 35 IIL.. 66. An evic-
tion is turning out of, or placing the party in such a situation that his
expulsion being inevitable he voluntarily surrenders possession to save
expenses. Reasoner v. Edmundson, 5 Ind., 393.
COVENANT OF WARRANTY. 337
been a partial or entire failure of title, but no eviction or
where there is an incumbrance that has not been paid off, the
grantee can maintain an action for a breach of his covenant,
but, as has already been said, he can only recover nominal
damages.‘ But where there has been an entire failure of title
and eviction, the measure of damages is the purchase money,
with legal interest.? In addition to this, when the grantee
has been put to expense in trying in good faith to maintain
his title, or in defending the same, he may recover such ex-
pense, including counsel fees.” This is on the ground that as
the plaintiff received no title by the conveyance he has lost no
land by the breach of the contract, and having lost the consid-
eration money with interest, he can recover it back with ex-
pense of former suits.®
XN
4 Nosler v. Hunt, 8 Ind. 212; Hocker v. Blake, 17 Ind. 97; Field on law
of damages. 367.
And where the grantee goes into possession under the deed, and his
title is fendered perfect by the statute of limitation, although there was
- abreach of covenant, yet he can only recover nominal damages. Wilson
v. Foles, 2 Duer 80; Cow v. Sill, 4 Duer 46.
3 Loey v. Marnan, 37 Ind. 168; Sheets v. Andrews, 2 Black 274; Over-
hiser v. McCallister, 10 Ind. 41; Burke et al. v. Clement, 16 Ind. 132;
Phillips et al. v. Rich est., 17 Ind. 120; Burton v. Reeds, 20 Ind. 88; Cin.,
Peru & Ft. W. BR. R. v. Pearce, 28 Ind. 502; 48 Ind. 385; Bickford v. Page,
2 Mass, 445; Matson v. Hobbs, 2 Mass. 433; Casewell v. Wendell, 4 Mass.
108; Nichols v. Walters, 8 Mass. 243; Leland v. Stone, 10 Mass. 459; Smith
v. Strung, 14 Pick. 128; Taple v. Lebrun, 1 Mo. 550; Hosford v. Wright,
Kirley (Conn.) 3; Stubbs v. Page, 2 Me. 378; Bonta v. Miller, 1 Little
(Ky.) 250; Cummins v. Kennedy, 3 Little 118; Martin v. Long, 3 Mo. 391;
Brant v. Foster, 5 Ia. 287; Phipps v. Tapler, 31 Mo. 463; Nutting v. Her-
bert, 29 Vt. 437; Wilson v. Forbes, 2 Den. N. C. L. 30; Heming v. With-
ers, 3 Bur. S. C. 458; Blossom v. Knox, 3 Chone, Wis., 295; Farmers’
Bank v. Glenn, 68 N. ©. 35; Vale v. Junction R. Co., 1 Cin. (C.) 571; 4
Kent com., 475; Field on law of dam , 368; Foster v. Thompson, 41 N. H.
373; King v. Gibson, admx., 32 Il. 348.
2Staats v. Ten Eyke, 3 Cain 111; Perkins v. Leavitt, 13 Vt. 379;
Scamour v. Harlan, 3 Dana (Ky.) 415; Daily v. Shirley, 8 Kans. 276; 4
‘ Kent, 534; Yokum v. Thomas, 15 Ia. 67.
3 Field on law of dam., 368.
In an action by a grantee on a covenant of general warranty, he may
338 LAW OF DAMAGES.
398. Objection urged to the Rule. The rule allowing the
plaintiff, in a case of a failure of title and eviction, to recover
back in the way of damages only his purchase money with in-
terest, has been severely criticised by men of great legal at-
tainments and forensic learning. It is contended that the
rule is in conflict with many well settled principles of law,
and favors the vendor. That the personal covenants in a deed
of conveyance of real property should be construed like other
personal covenants and contracts, and that when they are
broken, the damages occasioned by the breach should be as-
sessed in the same manner.
399. We will notice these objections. The general rule
for the assessment of damages in cases of breaches of contracts
is that the plaintiff may recover for all injuries resulting from
the breach that might have been seen by an ordinary forecast
of mind, or such damages as may reasonably be presumed to
have been in the. contemplation of the parties at the time of
making the contract, as the probable result of the breach of it.
Contracts, according to this rule, should never be construed so
as to run the intention of the parties beyond the comprehen-
sion of the finite mind. To contend that the vendee, in case
of a failure of title and eviction, shall recover the value of the
land at the time of the eviction, is either to ignore the rule
above laid down, or presume that the contracting parties pos-
sessed more than finite comprehension. For instance, suppose
that a vendor, a half century ago, had sold a piece of land in
some of the coal oil regions of Pennsylvania. At that time it
was a poor, barren tract, broken and hilly, worth, say, two dol-
recover money paid for copies of record, and for counsel fees in defend-
ing an action brought by a former owner to recover possession, and in
prosecuting the action to reform the first deed, if such expense were
necessarily incurred in obtaining paramount title. Laws v. Fury. 31
Ohio stat., 574.
COVENANT OF WARRANTY. 339
lars per acre. He got a mere trifle for it, and believing his
title good, he makes the grantee a warranty deed. A quarter
of a century afterwards his grantee bores an oil well upon the
premises and obtains oil in great abundance. The land, after
the completion of the well, becomes worth half a million of
dollars. Suit isbrought after its completion by a third person
who recovers the land by a paramount title. Can it be said
that the grantee should, in an action on his covenant of war-
ranty, recover by way of damages the value of the land, at the
time of the eviction, because at the time of the sale the par-
ties had foreseen or contemplated that such damages might
arise, when the fact of the existence of coal oil under the sur-
face of the earth had never, at that time been thought of by
the most learned scientist? Chancellor Kent, in the case of
Staats v. Ten Eyke, Ex., which was brought to recover dam-
ages for a breach of a covenant of warranty. Ten Eyke, dur-
ing his life time, sold two lots of ground in the city of Albany
to the plaintiff, with the covenant that he was rightfully
seized in his own right of a good, indefeasible estate of inher-
itance in the premises that he had full power to sell in fee
simple, and that the grantee should forever peaceably hold
and enjoy the premises without interruption or eviction from
any person whatever, lawfully claiming the same. Walsh
conveyed his moiety to Staats, who took possession thereof, and
afterwards sold one of them to Margaret Chim, with covenant
of warranty. The consideration paid was £300. Margaret
Chim was evicted,and brought suit on her covenant of warranty.
Staats brought suit against Ten Eyke’s estate, to recover on his
warranty. He said: Thiscase resolves itself into these two points:
1. Whether upon the covenants the plaintiff be entitled to re-
cover the value of the moiety of one lot at the time of the evic-
tion, or only at the time of the purchase, and to be ascertained by
the consideration given. 2. If the latter-be the rule of damages,
thenwhether the plaintiff be also entitled to recover interest.up-
on the purchase money and costs ofeviction. There are twocov-
340 LAW OF DAMAGES.
enant contained in the deed, the one that the testator was
seized in fee and had a good right to convey, the other that
the grantee should hold the land free from any lawful disturb-
ance or eviction. The present case does not state distinctly
whether the eviction was founder of an absolute title to the
moiety of one lot, or upon some temporary incumbrance. But
I presume from the manner of stating the question, and so I
shall presume the fact to be that the testator was not seized of
the moiety so recovered when he made the conveyance, and had
no right to convey it. The last covenant, then, in this case,
does not have any greater operation than the first, and I shall
consider the question as if it depended upon the first covenant
merely. At common law upona writ of warrantia charta, the
demandant can recover in compensation only the value of the
land at the time the warranty was made, and although the
land had become increased in value aftewards by the discovery
of a mine, or by building or otherwise, yet the warrantor was
not to render in value according to the then state of things,
butas the land was when the warranty wasmade. * * ¥*
This recompense in value, on excambium, as it was anciently
.termed, consisted of lands of the warrantor, or those which his
heirs inherited from him, of equal value with the land from
which the foffle was evicted. That this was the ancint uni-
form rule of the English law is a point, as I apprehend, not to
be questioned, yet in the early age of the feudal law on ‘the
continent, as it appears, * * * the lord was bound to rec-
ompense his vassal on eviction, with other lands equal to the
value of the feud at the time of the eviction. * * * But
there is no evidence that this rule ever prevailed in England,
nor do I find in any case that the law has been altered since
the introduction of personal covenants to the disuse of the an-
cient warranty. These covenants have been deemed prefera-
ble because they secure a more easy, certain and effectual re-
covery. But the change in the remedy did not affect the es-
tablished measure of compensation, nor are we at liberty now
COVENANT OF WARRANTP. 341
to substitute a new rule of ‘damages from mere speculative
reasoning, and that, too, of a doubtful solidity. * * * Upon
the sale of land the purchaser usually examines the title for
himself, and in case of good faith between the parties (and
of such cases only I now speak) the seller discloses his proof
and knowledge of the title. The want of title is therefore
usually a case of mutual error, and it would be ruinous and op-
pressive to make the seller responsible for any accidental or ex-
traordinary rise in the value of the land. Still more burden-
some would the rule seem to be if that rise was owing to the
taste, fortune or luxury of the purchaser. Noman could ven-
ture to sell an acre of land to a wealthy purchaser without the
hazard of absoluteruin. * * * If this question was now
res integra, and we were in search of a fit rule for the occasion, I
know of none less exceptionable than the one already estab-
lished. * * * The next point arising in this case is wheth-
er the the plaintiff is entitled to recover interest upon the
purchase money, and the cost of eviction. It is evident that
originally the vendee recovered only what was deemed equiv-
alent to the purchase money without interest, for he recovered
other lands, equal only in value to the lands sold at the time
of the sale. The rule would have been the same at this day
had not the action for mesne profits been introduced, which
takes away from the purchaser the intermediate profits of the
land. As long as he was permitted to reap the rents and prof-
its they formed a just compensation for the use of his money.
Whether the action for mesne profits has not been carried too
far in our law by extending it to all cases instead of confining
it to a modified possession, it is now too'late to inquire. * *
Iam of the opinion that the seller is generally bound to an-
swer for interest for the purchase money, and that the interest
ought to be commensurate in point of time to the legal claim
to mesne profits. This right to interest rests on very plain
principles. The vendor has the use of the purchase money,
and the vendee loses the equivalent by the loss of the mesne
342 LAW OF DAMAGES.
profits. The interest ought to commence from the time of the
loss of the mesne profits. * * * As to the costs of the
suit attending the eviction, stated in the case it is very clear
that the defendants are responsible under the covenants, for
the.testator was bound to defend and protect the plaintiff in
his assigns, in the titlehe had conveyed. * * * My opin-
ion accordingly is that the plaintiff in the present case is en-
titled to recover the consideration paid for the moiety of the lot
evicted, together with interest thereon from the date of the
purchase, and the costs of the suit in ejectment for the recov-
ery of the same.’*
400. Objection to the Rule. But this rule has been rejected
in Massachusetts, Maine, Vermont, Connecticut and Louisi-.
ana, and the rule adhered to during the reign of the feudal
system adopted, that the grantee shall recover the value of the
land at the time of the eviction, without regard to the consid-
eration paid therefor, and in some of them, in addition thereto,
the expense incurred in defending the eviction suit, including
attorney’s fees.” The argument in favor of this rule has al-
ready been considered briefly, but for the purpose of giving the
student a clearer conception of the basis upon which it rests,
we will notice it more in detail.
Judge Spencer, in the case of Picker v. Livingston, re-
views the argument of Kent in the case of Staats v. Ten Eyke,
and in commenting on the question he takes issue with the
3 Caines (N. J.) 111; Sedgwick, leading cases on the measuae of dam-
ages, p. 4.
"Gore v. Bazire, 3 Mass, 526; Sweet v. ‘Patrick, 12 Me.,9; Keeler v.
Wood, 30 Vt., 242; Swett v. Sprague, 40 Vt., 43; Biglow v. Jones, 4 Mass.
512; Wyman vy. Ballard, 12 Mass., 304; Sterling v. Peet, 14 Conn., 245;
Elder v. Tene, 32 Me., 104; Webber v. Coussy, 12 La. An., 535; Sarpy v.
New Orleans, 14 La. An., 311.
COVENANT OF WARRANTY. 343
learned Chancellor on many points discussed by him in that
case. Hesays: “This question, I think, has not been settled
in the English courts. It has never been decided in our own,
and consequently it appears to me, we are at full liberty to fix
the rule which shall bear analogy to other cases, and attain
complete justice between the parties. I cannot pretend to say
that the rule I shall lay down shall be free from objections
when applied to all cases and I am not sensible that any gen-
eral rule in almost every given case will invariably be free
from exception. It is the very nature of a general rule.
Sometimes it operates harshly, but the necessity of a fixed
standard of justice is of more importance to the interest of
men than one which is capricious and fluctuating. It has, I
think, been erroneously said that the defect of titleis a case of
mutual error. On the contrary, from my observation and
knowledge of the sale of land, I think the defect of a title is a
matter generally and almost universally in the peculiar
knowledge of the vendor. It isa rare case for a purchaser to
investigate the seller’s title, and in most cases it is impossible
The buyer relies on the allegation of the vendor on his apparent
responsibility to reimburse in case of eviction, upon his pos-
session of the property, and emphatically on his covenants of
title and for quiet enjoyment. These covenants, where they
occur in a deed, seem to me to indicate beyond all question
that the purchaser did not mean to relie on the title of the
vendor alone, but that he meant to have his personal liberty
as his guaranty, The language of the vendor corresponds
with that of the purchaser, and holds out the idea that he had
sold the land at his own peril, and that he would warrant it
to be his. Extravagant cases have been put hypothetically to
show the erroneous injustice of the rule that the vendor must
be answerable for improvements. It has been asked if a piece
of land thus sold with covenant should become the site of a
flourishing city, that the vendor must be answerable for im-
provements and withstand ruin. It may be retorted, what is
844 LAW OF DAMAGES.
to become of the industrious citizen or mechanic, who has
spent his hard earnings in erecting his little house or work-
shop, relying on the covenant in his deed, if he can only get
back his purchase money with interest? It is not fair, how-
ever, to test the rule by extreme cases. To settle a general
rule wisely and equitably, we should have an -eye to a case
which generally occurs, and not to be startled on the one hand
or the other by those occurrences which are rare and few. In
general a defect of title happens in sales between man and
man, where the improvements are of ordinary and beneficial
kind. Ifthe improvements are merely to gratify the eye of
the individual, and to pamper his vanity and pride, a jury would
be warranted to take those things into consideration in their
assessment of damages. I lay it down as a rule which cannot
require much illustration to enforce it on the score of analogy
and justice, that in an action fora breach of covenant the
damages are to be estimated according to the value of the thing
when the covenant was broken. Thus in covenant for the de-
livery of specific property at a given day. In caseof a failure
the rule is invariably to allow in damages the value of the
thing on the day it ought to have been delivered, and when the
covenant was broken. So also on contract for the delivery of
stock, the value at the time it ought to have been delivered,
and even at the time of trial has beon the criterion of dam-
ages. * * * In the present case the defendant covenanted
that the plaintiff should quietly enjoy the land sold. This
covenant was violated when the plaintiff was evicted, and he
has lost by the breach of the covenant, not only the quiet en-
joyment of the land, but the usufruct of those evictions and
improvements without which it is fair to say that the land it-
self could not have been enjoyed agreeable to the intention of
the parties. It necessarily follows that had the defendant kept
his covenant, and allowed the plaintiff to enjoy the premises
sold, he would not have been deprived of those improvements.
I confess myself incapable of perceiving, when he has under-
COVENANT OF WARRANTY. 845
taken for a price paid to assure to the vendee the validity of
the title. Very often, and perhaps generally, there is a want
of due caution on the part of the vendor, who sells without |
title, and not infrequently there is a mixture which sets de-
tection at defiance. The rule I have advanced, while it will
restore to the innocent vendee no more than he has actually
lost, will induce greater caution in sellers, who, if only respon-
sible for the principal and interest, will find the selling of land
without title an easy and excellent method of raising money,
instead of resorting to borrowing.’””
401. The Reason for Both Rules. The are several good argu-
ments and reasons that can be produced in favor of each of the
rules now under consideration, as well as several well-grounded
objections, and we are led to the opinion that no general rule
can be laid down in this class of cases that will be free from
‘objections. The advocates on both sides have seen the hard-
ships that the enforcement of their rule would bring about,
and have attempted in vain to cover them up by holding up
in the strongest light the evils that would result by the en-
forcement of the rule laid down by the others. Ithasoccurred
to us that a more just and equitable rule than either of these
we have been considering, might be laid down and enforced.
It is admitted by the advocates of both of the old rules that
the intention of the contracting parties should govern and be
enforced. And this is in accordance with the rule laid down
for the construction of contract. In order to ascertain their
intention, the court or jury trying the cause should take into
consideration the character of the country, and soil, the loca-
tion of the land, the prospective value, and, in fact, all the
surrounding circumstances, and then say what was the inten-
tion of the parties, at the time the contract was made. If,
14 Johns(N. J.) 1.
346 LAW OF DAMAGES.
from these facts, the jury can discover no evidence of the in-
tention or understanding of the parties at the time of the sale,
then they should find for the plaintift in the amount of the
purchase money with interest. But to this rule there arises a
well grounded objection, and it is this: On a subject of such
general interest and concern as the usual covenants in a con-
veyance of land, the standard for the computation of damages
upon a failure of title ought, at least, to be certain and notori-
ous. The parties are each equally interested in having the
rule definite and fixed. And we have arrived at the conclusion
after a careful examination of the authorities, that the rule al-
lowing the vendee, in case of a breach and eviction, to recover
back his purchase money with interest, is about as free from
objections as any that can be laid down.
402. Damages where Part of a Tract is Taken. Having con-
sidered the measure of damages in case of an entire failure of
title and eviction, we will now proceed to notice other
breaches, where the damages may be less than the purchase
money, with interest. Where there is a failure of title to a
part of a tract of land, purchased and taken possession of,
and there is no recision of the contract on that account, the
measure of damages on eviction from such part in the absence
of special circumstances is a sum bearing the same proportion
to the prices of the whole that such part bears to the entire
tract of land, with interest and expenditure in defending the
title?
? Hoot v. Spade, 20 Ind., 326; Philips v. Ruch., 17 Ind, 120 Kent’s
com., sec. 477; Morris v. Phelps, 5 Johns. R., 49; Gurther v. Pugsley, 12;
John 126; Wager v. Scuyler, 1 Wend., 555; Denmick v. Lockwood, 10
Wend , 142; Griffith v. Reynolds, 1 How. (U. S.), 609; Rawle on covenant
of title, 2 ed., 110, Funiss v. Ferguson, 15 N. Y., 437; Giles v. Durgo, 1
Duer, 331; Sedgwick on measure of damages, 17; Michaels v. Mills, 15
Ohio, 604; Wiley v. Howard, 15 Ind., 169; Bond v. McQuattleboum, 1
McCord, 584; McAlpin vy. Woodruff, 11 Ohio st., 120; King v. Kersey, 5
COVENANT OF WARRANTY. 347
408. Right of the Plaintiff to Recover Interest. The right of
the plaintiff to recover interest on the purchase money, has
not been adopted in this country without qualification. It is
evident that originally the plaintiff recovered what he deemed
equivalent to the purchase money without interest, for he only
got a tract of land equal in value to the one he purchased at the
time the conveyance wasmade. Atthat time, however, a plain-
tiff in ejectment could not recover the mesne profits. But sub-
sequently the action for mesne profits was introduced, and the
purchaser, on eviction, was compelled to pay for the rents and prof-
its of theland,while heoccupiedit. Aslongas he was permitted
to reap the rents and profits they were considered equal to the
interest on the purchase money. The action for mesne profits
is almost universally recognized in this country, therefore, inan
action on a covenant of warranty for damages in case of afailure
of title and eviction, it will be presumed that the plaintiff has
lost the mesne profits until the contrary is established. The right
to recover interest rests on very plain principles. The vendor
has the use of the purchase money, and the vendee loses the
equivalent by the loss of the mesne.profits. The interest ought
ta be computed from the time of the loss of the mesne profits.
And if the land was improved, and the plaintiff occupied it, and
was not compelled to pay any mesne profits, he should only be
allowed to recover his purchase money.’
Ham. O. R, 98; Backus v. McCoy, 3 Ham., O. R., 211; Foot v. Burnett,
10 Ohio, 326; 4 Hale, 148; 2 Black. 274; 8 Pickering, 455; 10 Conn., 442;
Daniels v. the State, 16 Ind , 456; Field on dam., 369
7 Staats v. Ten Eyke, 3 Cains (N. J.) 111; Sedgwick, leading cases on
Measure of Dam.; 4 Field on the law of dam., 393; Sedgwick on the mea-
sure of damages, p. 170-171 and notes. Where land has been conveyed
with covenant of warranty, and the vendee is evicted by a title bara-
mount, the measure of damages is the value of the land as shown by the
consideration paid, with interest, but if it be improved land, and the
vendee has been in possession his claim to interest is thereby extin-
guished except for the term he has been compelled to account for mesne
profits, Cox v. Henry, 32 Pa. st, 18.
Sumner v. Williams, 8 Mass., 222; Gurther v. Pugley 12 Johns, 126; Pat-
348 LAW OF DAMAGES.
404. The Rule of Full Compensation Applied. The old rule
of full compensation for all loss sustained, that we have re-
ferred to so often in this work, applies in all actions for a
bréach of covenant or agreement in reference toland. And
where it appears that the plaintiff’s loss has been less than the
purchase money with interest, his recovery will be limited to
the actual loss sustained. “Thus, where the grantor was
seized of two-sixths of a tract of land, and only had a life es-
tate in the remainder, it was held that the damages for a
breach of the covenant of seizin in such cases was not the four-
sixth part of the purchase money or consideration paid, but
that amount less the value of the estate during the life of the
grantor, and the value of such life estate may be estimated by
a table of expectation of human life, recognized as authority,
such as the Carlisle life table, and the life table of Dr. Wiggles-
worth.” .
404. The student should remember that the rules for the
assessment of damages upon covenants in deeds for the con-
veyance of real estate, have been passed with a view of giving
the grantee full compensation for the damages he has sustained.
Thus, if the covenant of seizin is broken, and the grantee
evicted, and there is a total failure of title, the law restores to
the purchaser the consideration paid, with legal interest. But
in this, as well as in other covenants in deeds of conveyance,
if there is anything that would render that rule inequitable,
the court or jury trying the cause should take it into con-
sideration. The sole object of a covenant of this kind is to se-
cure the plaintiff a legal seizin in the land conveyed. If it is
terson v. Stewart, 6 Watts & Seg., 528; Riles, Admr., v. Frauntleroys,
Admr., 9 B. Monroe, 720; Wilbom v. Beeman, 2 Devreaux, 488; Rawle
on com. title, 117.
? Miller v. Catlin, 22 Vt., 98; Donaldson v. the M. & M. Railroad Co.,
18 Ia., 280.
COVENANT OF WARRANTY. 349
broken, and he fails of his seizin, he has aright to the pur-
chase money with legal interest. But if he has, by another
deed, or another covenant in the same deed, which was also
taken to assure to him the subject matter of the conveyance
he has obtained that seizin, it would be inequitable that he
should have the seizin and be allowed to recover back from the
grantor the purchase money with interest.’ Thus, where the
grantor, after a breach of covenant, and even after suit brought
for a breach acquired the title, it was held that such subse-
quently acquired title inured to the benefit of the grantee, and
went in mitigation of damages. So, where a failure of title
has been such as to constitute a technical breach of a covenant
of seizin, but was not such as visited upon the plaintiff the
loss of the land or any part thereof, he can only recover nom- :
inal damages.‘
406. After Acquired Title Inures to Purchaser. It may be con-
sidered well settled that where a grantor conveys land with a
full covenant of warranty, and he afterwards acquires by pur-
chase or otherwise, a paramount title, it immediately inures to
the purchaser or those claiming under him by operation of the
doctrine of estoppel. And in case the grantor, who has pur-
chased the outstanding title, is sued for a breach of covenant
of warranty, he may show in mitigation of damages that he
has completed the plaintiff’s title by purchasing the outstand-
ing title, which is the breach complained of.
Baxter v. Bradbury, 20 Me., 260; Whiting v. Dany, 15 Pick., 428
Lockwood v. Sturdevant, 6 Conn., 313; Turner v. Livingstone, 12 Wend., |
83; Morris v. Phelps, 5 Johns, 49.
4Nosler v. Hunt, 18 Ia., 212; Barber v. Cobert, 28 Ia., 317; McGay v-
Hastings, 39 Cal., 360; Cornell v. Jackson, 3 Cush., 506; Lawless v. Col-
lier, 19 Mo., 480; Ouer Hiser v. McCollis, 10 Ind., 41; Martin v. Baker, 5
Blackford, 232; Parker v. Brown, 15 N. H., 176; Howell v. Richards, 11
East., 663; Rawle on cov. title, 105.
5 Jackson v. Wihslow, 9 Cow., 18; Kellogg v. Wood, 4 Paige; Rawle on
cov. of title, 414; Sparrow v. Kingman, 1 Comstock, 247; Rathburn v,
350 LAW OF DAMAGES.
407. Does a Covenant of Seizin Run with the Land. There is
some confusion among the authorities as to the correctness of
the rule adopted by the majority of the courts of this country,
that if there is no seizin of the land in the grantor, there is at
once a breach of the covenant, and a claim for damages, and
that such breach will not run with the land, and that it can-
not be assigned by a subsequent conveyance.’
408. The American rule will operate oppressively in all
cases where land has been subsequently conveyed by the
grantee either toward the grantor or subsequent purchaser.
Rathburn, 6 Barb., 8. C., 226; Hoyt v. Dimon, 5 Day, 479; Dudley v. Cad-
well, 19 Com., 226; Sherwood v Barlow, ib., 476; Lawry v. Williams, 13
Missouri, 282; Baxter v. Bradbury, 20 ib., 260; Pike v. Galvin, 29 Me.,
185; Farland v. Williams, 7 Greenl., 96; William v, Thurlow, 31 Me.,
395; Kimball v. Blaisdell, 5 N. H., 533; Mark v. Willard, 13 N. H., 389;
Wade v. Eindsy, 5 Pick., 413; Blanchard v. Brooks, 12 Pick., 47; Gibbs v.
Thayer, 6 Cush., 30; Gough v. Bell, 1 Zalerokie, 167; Douglas v. Scott, 5
Ghio, 194; Scott v. Douglass, 7 Ohio, 227; Barlow v. Morris, 15 Ohio, 408;
D swell v. Buchanan, 3 Leigh, 376; Masse v. Sebastian 4 Bibb., 436;
Logan v. Steel, 4 Monroe, 433; Logan v Moore, 7 Dana, 76; Rigg v. Cook,
4 Gelaim, 348; Robertson v. Gaines, 2 Humph.. 383; Kennedy v. McCar-
thy, 4 Porter v. Welsh, 17 Ala., 772; Terret v. Taylor, 9 Cranch, 52; Ma-
son v. Manchester, 9 Wheat, 455; Reeder v. Craig, 4 McCord, 411, and
Harris, lessee, v. Morris, I McLean, 44. By the common law, if a grant-
or who has no interest, or only a defeosible interest in the premises
granted, convey the premises with warranty and aftewards obtained an
absolute title to the property, such title immediately becomes vested in
grantee or his heirs or assigns by estoppel. Coke Little, 565; Jackson v.
Wright, 14 Johnson, 193; Gochenour v. Mowry, 33 Ill, 331; Schofield v.
Homestead Co , 32 Ia., 317.
"Mitchell v, Warren, 5 Conn., 497; 4 Kent, 472; Eewis v. Ridge, Cro
Eliz, 863; Com. Dig title, Com. B, 3; Andrew v. Pearce. 4 Bos. & P., 158;
Gloster v. Audley, 7 Ray, 14; Hamilton v. Wilson, 4 John, 72; Logan v.
Moulder, 1 Pike, 328; Clark y. Swift, 3 Md., 390; Greenley v. Wilcocks, 2
Johns, 1; Kerr v. Shaw, 13 Johns, 236; With v. Mamford, 5 Com., 137;
Bing v. Haven, 3 A. R., Mash, 324; Marston v. Hobbs, 2 Mass., 4395
Chapman vy. Holms, 5 Holst, 20; Dale v. Sincly, 8 Kans., 276.
It appears to us to be a mistake to say that the seizin cannot pass to
the heirs or assigns of the grantee. The covenant is not inserted in the
deed merely for the grantee’s benefit, but for the benefit of all others
COVENANT OF WARRANTY. 351
And we believe that this doctrine is gradually declining in fa-
vor of the English rule,which is that a covenant of seizin runs
with the land.’’ The English rule has been established in most of
those States where therulesof the common law,which forbid the
assignment of a chose in action, have been abolished. This
strikes us being the most reasonable and just of the two. The
object-of all covenants in deeds of conveyance is to secure the
grantee against losses that he may sustain if his title is defect-
ive, and he is injured thereby. The transfer’of the land car-
ries with it the covenant or the security that the vendor has
to indemnify him against all losses occasioned by a breach of,
his warranty. This indemnity can be of no further benefit to
the subsequent grantor, for he has no longer any interest in
maintaing the title. It has passed from him and is vested in
his grantee. The grantee must be the first and only sufferer if
thé title proves defective, and he should therefore receive the
indemnity. It may be that he could recover on the covenant
in his deed against his original vendor.. But suppose that, he
has taken the benefit of the bankrupt law, and is totally in-
solvent. In that case the grantee would be without a remedy
and must lose his purchase money, interest, andexpense. But
his grantor, who has lost nothing by the breach, could sue for
the breach of covenant in his deed, and recover back his pur-
chase money with the value of the land at the time of the
eviction, while yet retaining the purchase money received
from his grantee. But suppose that the subsequent grantee
purchased the land without a warranty, and pays full value
for it, and is afterwards evicted, he is without a remedy, but
who may derive their claim to the land through him. Whoever thus
derives his right, and ultimately sustains damage in consequence of the
covenantor’s want of title, may sue him for the breach. It is said in one
of the oldest and best books of the law that-if a man makes a covenant by
deed to ancther, his heirs and to enfeoff him and his heirs of the
amount. Matenv. Baker, Admr.,5 Blackf. (Ind.) 232.
1 Kingdom v. Nottle, 1 Maule & Shu., 355; 4 ib, 58; King v Jones, 5
Taunt., 418; 4 Maule v. Schu 188; Wash. on real prop., 649.
852 LAW OF DAMAGES.
his grantor, who holds under a warranty, may recover from his
grantor his purchase money with interest, when he received
no injury, and his grantes, who is the only real party injured,
can recover nothing. Such a rule is unjust, and is calculated
only for the benefit of those who seek to take the advantage of
others.*
409. Covenant for Good Right to Convey. The covenant for
good right to convey is very generally said to be synonymous
with that we have just been considering. A covenant of this
kind is useless when preceded by a covenant that the vendor
is seized of an indefeasible estate, of inheritance in fee simple.
And in most of the modern conveyances this covenant is
omitted? For measure of daniages in case of a breach of this
covenant, see covenant of seizin.
410. Covenant Against Incumbrance. Having noticed the
damages that the grantee may recover for a breach of cove-
nant of seizin and right to convey,. we will now notice the
damages that the purchaser may recover for a breach of cove-
nant against incumbrance. An incumbrance may be defined
to be every right or interest in the land conveyed that will
diminish its value. Any weight on the land that lessens its
value.
411. Damage where the Incumbrance has not been Removed. This
covenant is treated asa covenant of indemnity, and no rule is
better settled than that if the incumbrance is still contingent
1 Schofield v. Iowa Homestead Co., 32 Ia., 317; Matin v. Baker, 5 Black
(Ind ) 232; 4 Kent’s com., 472.
? Hughes Practice of Sales of Real Property, vol. p. 411; Rawle on Cov-
enant of Title, p. 127-128; Field on the law of damages, sec. 460; Pitcher
v. Livingstone, + Johns, 1. The covenant of seizin, which relates to the
title, is the principle and superior covenant to which the covenant for
quiet enjoyment which goes to the possessor is inferior and subordinate.
Pitcher v. Livingstone, 4 Johns, 1.
COVENANT OF WARRANTY. 853
P :
in its character and if nothing has been paid by the pur-
chaser’ towards removing or extinguishing it, and if it has
inflicted no actual injury upon him in a suit for a breach of
this covenant, he can only recover nominal damages. He will
not be allowed to recover certain compensation for running the
Tisk of an uncertain injury.
The reason for this rule is that where the grantee has not
paid or removed the incumbrance, nor been evicted from the
premises by reason of it, he shall not recover back the purchase
money while he still holds possession and may never be evicted
or turned out of ‘possession. He must first pay off the incum-
‘brance, so that it cannot afterwards prejudice the grantor be-
fore he can recover substantial damages.®
° Prescott v. Truman, 4 Mass. 627; Grant v. Tallman, 20 N. Y. 191;
Treft v. Adams, 8 Pick. 547; Harlow v. Thomas, 15 Pickering 66; Stowell
v. Bennett, 34 Me. 422; Anderson v. Davidson, 17 N. H. 413; Smith v.
Jefts, 44 N. H. 482: Mason v. Cooksy, 51 Ind. 519; Vane v. Lord Barnard
Gilbert, Eq. Rep. 7, per Lord Comper; Bean v. Mayor, 5 Maine 94; Ran-
dell v. Mallett, 14 Me. 51; Herrick v. Moore, 19 Me. 313; Clark v. Perry,
30 Me. 151; Richardson v. Dow, 5 Vt. 9; Davis v. Lyman, 6 Conn. 255;
Wyman v. Ballard, 12 Mass 304; Jenks v. Hopkins, 8 Pick. 348;
Leffingwell v. Elliott, ib. 457; Brooks v. Moody, 20 Mass. 474; Cum-
mings v. Little, 24 Pick. 269; Pitcher v. Levingston, 4 John 10; Dela-
vergen v. Norris, 7 Johns 358, Hall v. Dean, 13 Pick. 100; Stannard
v Eldrege, 16 Johns 125; Baldwin v. Munn, 2 Wend. 405; Gilbert
v. Minn , 1 Comst. 563; Patterson v. Stewart, 6 Watts & Seg. 528; Foot v-
Burnett, 10 Ohio 317; Whistler v. Hicks, 5 Black 100; Smith v. Ackerman,
5 Black 541; Pomeroy v. Burnett, 8 Black 143; Rawleon cov. of titles, 155;
Field on the law of dam., sects. 450-451; Arrigoni v. Johnson, 6 Weg. 167.
There need not be a dispossessing by process of law to constitute an
eviction. 51 Ind. 519.
3 Prescott v. Truman, 4 Mass. 125.
An outstanding mortgage constituting a breach of covenant that the
land is unencumbered, but until the purchaser has been evicted only
nominal damages can be recovered for his breach. Reasoner v. Ed-
munson, 5 Ind. 393; Barker v. Hobbs, 6 Ind. 383.
Incumbrance on real estate conveyed by deed contains a covenant
against incumbrance, and are not presumed to be excluded from the
operation of the covenant, because their existence was known to the pur-
354 LAW OF DAMAGES.
412. Damages Where the Incwmbrance has Inflicted an Actual
Injury. The general rule of damages in such cases is to make
good the actual loss of the purchaser in case of a breach, or to
allow the plaintiff such a sum as would place him in the same
position as if the covenant had never been broken. In other
words, the grantee is to be fully compensated for the loss he
has sustained. Therefore, if the plaintiff has extinguished the
incumbrance on the land he may recover of the defendant the
amount paid by him for such purpose and interest, but in no
case can he recover an amount in excess of the purchase money
with interest.
4138. We have shown how the rule for the assess-
ment of damages in case of a failure of title and eviction
varics in different States. In some it is held that the
covenantee can recover only his purchase money with in-
terest, including necessary expense in upholding his title. In
others, that he may recover the value of the estate at the time
of eviction. In those States where the former rule has been
adopted they hold that the vendee who has paid off an incum-
brance may recover whatever he has paid, with legal interest,
provided it does not exceed the purchase moncy and interest,
and that the ultimate extent of the vendee’s recovery is the
_chaser at the time of the execution of the deed. Medler v. Heath, 8
Ind. 171; Snyder v. Lane, 10 Ind. 424.
* Foot v. Burnett, 10 Ohio 317; 4 Kent com. 476; Field on the law of
danages, sec. 450; Davis v. Lyman, 6 Conn, 255; Wyman v. Brigden, +
Mass. 150; Wyman vy. Ballard, 12 Id. 304; Chapel v. Bull, 17 Id. 221;
Tufts v. Adams, 8 Pick. 549, Brooks v. Moody, 20 Id. 470: Cummings v.
Little, 24 Id. 266; Bochelder v. Sturgis, 3 Cush. 205; Waldo v. Long, 7
Johns 173; Delvergen v. Norris, Id. 358; Hall v. Dean, 18 Id. 105; Stand-
ard v. Eldrege, 16 Id. 254; Brown v. Broadhead, 3 Wharton 104; Funk v.
Voneda, 11 Surg. & Rawle 112, Cane v. Allen, 2 Dowe 296; Henderson v.
Henderson, 13 Missouri 162; 10 Wend. 142; St. Louis v. Bliss, 46 Mo. 157;
Farmers’ Bank v. Glenn, 68 N.C. 35; Kent vy. Cantrall, 44 Ind. 452; Rar-
den v. Walpole, 38 Ind. 146; Field on the law of damages, sec. 450; Rawle
on cov. of title, 158; McGary v. Hasting, 39 Cal. 360.
COVENANT OF WARRANTY. 355
purchase money with interest and the necessary expenses for
a breach of any or all the covenants in hisdeed. But in those.
States where the latter rule prevails, they hold that the vendee
who has liquidated and paid off an incumbrance may recover
back the money paid with interest and necessary expense in
defending his title, provided that amount does not exceed the
value of the land at the time of the eviction, and in no case
can the recovery exceed that amount.®
414. Where the Incumbrance Cannot be Recovered. It fre-
quently happens that the incumbrance cannot be removed as
where it consists of a right of way ora lease. The covenant of
seizin is not broken, however, by the existence of a public
highway, which has been established by the right of eminent
domain and is in actual use. The freehold still technically re-
mains in the owner of the soil and passes to the purchaser.‘
But where an incumbrance exists that cannot be removed the
vendee can recover such damages as he may sustain thereby,
whether he knew of the existence of the incumbrance or not."
And if he is permanently kept out of the estate by reason of
§ See on-first rule laid down in this section 4 Kent's com. 474; Field
on the law of damages, sec. 446; Porter v. Bradley, 7 R. I. 538; Fawcett v;
Wood, 5 Ia. 400. On the second rule see Norton v. Babcock, 2 Met. 510.
Barrett v. Porter, 14 Mass. 143
Where land is sold with acovenant against incumbrance and an in-
cumbrance exists of a permanent character which impairs th2 value of
the premises and cannot be removed as a matter of right by the pur-
“chaser, the damages will be measured by the diminished value of the
paemises. Mitchell v. Stanley, 44 Conn. 312.
When the incumbrance has been removed the plaintiff can recover the
amount paid to clear his title. Curther v. Russell, 46 Ia. 269; McClel-
land v. Moore, 48 Tex. 355; Taylor v. Barnes, 69 N. Y. 480.
6 Scribner v. Holmes, 16 Ind. 142.
1 Rawle on covenant for title, 115 to 120, 44 Conn. 312; Butlar v Yeil,
27 Vt. 739; Kellogg v. Martin, 50 Mo. 496; Van Wagner v. Van Nortrand.
19 Ia. 422; Barlow v. McKinly, 24 Ia. 69; Beach v. Miller, 51 Ill 206;
Hubbard v. Norton, 10 Conn. 422; Rea v. Menkler, 5 Law (N Y.) 196;
ady v. Allen, 22 Barb, 388, Church ¢. Higgins, 48 N. J. 532.
356 LAW OF DAMAGES.
the incumbrance, he may recover the purchase money with
interest.”
415. The student will see at a glance that this covenant
is closely related to that of a covenant of quiet enjoyment or a
general warranty. Anda cuse frequently occurs where what
was at first a breach of a covenant against incumbrance ripens
into a breach of the covenant for quiet enjoyment or of general
' warranty, as where the incumbrance is a mortgage or judg-
ment lien, which, after foreclosure and sale, may divest the
grantee of the title and right of possession, either by voluntary
surrender of the premises on execution or on eviction. Where
an action is brought for a breach of covenant in a deed the
plaintiff must allege and prove the breach, and this rule ap-
plies where the-plaintiff is evicted by paramount title as well
as in all other cases. The onus in all this class of eases is on
the plaintiff!
416. Covenant for Quiet Enjoyment and of Warranty. We
have thought proper to consider these covenants together, as
substantially the same rules for the assessment of damages are
applicable to each. The plaintiff in order to recover for a
breach of either of these warranties must show that he has
sustained actual damage. It is not sufficient that there is a
paramount legal title in another, but he must show a disturb-
ance of the possession or an. eviction from the premises by a
superior title in order to recover substantial damages. And in
wn action for a breach of either of these covenants it is well set-
7 Sedgwick on dam., 178; Willett v. Burgess, 34 Ill. 494; Grant v. Tall-
man, 20N. Y. 191; Giles v. Dugre, 1 Duer 331; Potter v. Bradley, 7 k. I.
538; Cady v. Allen, 22 Barb. 388; Funk v. Caswell, 5 Ia. 62; Field on law
of dam., sec. 450
‘Colman v. Ballard, 13 La. 512; Thomas v. Stickel, 13 Ia. 714; Kent’s
com. +74; Patterson v. Stewart, 6 W. & S. Pa. 527; Barlow v. McKinly, 24
Iowa 69; Field on the law of damages, sec, 469. :
ee
COVENANT OF WARRANTY. 357
tled that the rule of damages where there has been an actual
loss of the premises is the purchase money with interest.
Where the plaintiff has actually purchased the paramount
title, it is the sum actually and in good faith paid for the par-
amount title and the amount expended in defending his pos-
session, provided such damages in no case exceeds the pur-
chase money and interest.’ ,
417. Exception to the Rule. But the rule allowing the re-
covery of purchase money with interest does not apply to
executory contracts when the vendor has sold land to which
he has not a perfect title and where he undertakes to complete
and perfect it. In such cases there is an expressed agreement
for indemnity, and the rule of damages as a measure of in-
demnity is the value of the land at the time of the eviction or
other breach with interest from that time.’
418. Thus it was held that when the defendant who had
exchanged a tract of land in the State of Indiana for a tract in
the State of Olio and afterwards agreed to cancel all incum-
brance on the Indiana land in six months and failed to do so,
and the plaintiff lost his land, that for the breach of such an
executory contract the plaintiff could recover such damages as
were the necessary, natural and probable result of the breach com-
plained of; that such was the general rule, and that it rested
upon the principle of obvious justice ; and that the measure of
damages was the value of the Indiana land with interest
thereon, *
2 McGary v. Hasting, 39 Cal. 360; Green v. Tallman, 20 N. Y. 191; 4
Kent’s com. 468-469; Black’s com. 298; Field on law of dam , sec. 460.
® Taylor v. Barnes, 69 N. Y. 430; Trule v. Granger, 4 Seld. 115; Hop-
kins v. Grozback, 6 B. & C. 31; Hill v. Hobart, 16 Maine 164; Brinkerhoff
v. Phelps, 24 Barber 100; McDonnell v. Dunlope, Hardin 41; Fletcher v,
Button, 6 Barber 646.
4 Manahan v. Smith, 19 Ohio’ st. 384; see also Lloyd v. Quinley, 5 Ohio
358 LAW OF DAMAGES,
419. Costs and Counsel Fees. The authorities are not uni-
‘orm upon the question as to the right of a plairitiff to recover
costs and counsel fees incurred in defending his title, but it
has recently been held in several of the States that the dam-
ages on a breach of warranty ia a deed is the value of the
property at the time of the conveyance with interest thereon,
and necessary costs a id expenses.’ There is a co..flict among
the authorities as to the right of the plaintiff to recover coun-
sel fees in this class of cases, but the fact is now being pretty
generally recognized ‘by the court that men who have no legal
learning are not capable of conducting suits in courts, and,
therefore, the employment of an attorney skilled in the prac-
tice of his profession becomes an absolut necessity, and the
expense paid out for such service are a necessary part of the
costs.’
420. Mitigating Circumstance. The grantor may show in
mitigation of damages that subsequent to the breach com-
plained of he acquired the outstanding title which enures by
estoppel to the plaintiff by virtue of his covenant of warranty,
and in this way reduce the plaintiff’s recovery to nominal
damages only.2, And if he can show that the vendee’s title has
been perfected either by the statute of limitation or otherwise
st. 265; Rawle on com. titles, 141-146-153; Wade v. Comstock, 11 Ohio
st. 71 81; Winslow v. McCall. 32 Barber 241.
5 Robertson v. Lemon, 2 Bush (Ky.) 301; Dalton v. Baker, 8 Nev. 190;
Keeler y. Wood, 30 Vt. 242; Smith v. Sprague, 40 Vt. 43; Rowe v. Heath,
23 Texas 374.
* Staats v. Ten Eyke, 3 Cains (N. Y.) 111; Robertson v. Lemon, 2 Bush
(Ky.) 801; Dalton v. Baker, 8 Nev. 190; Keeler v. Wood, 30 Vt. 242;
Smith v. Sprague, 40 Vt. 43; Rowe v. Heath, 23 Texas 314; Yakano v.
Thomas, 15 Ia 67; Jetter v. Glenn. 9 Rich. 314; Demick v. Lockwood, 10
Wend. 142; Cox v. Henry, 32 Pa. st. 18.
" Rawle on cov., 105; Baxter v. Bradbury, 20 Me. 260; Reese v. Smith,
12 Missouri 343.
COVENANT OF WARRANTY. 359
he can reduce the plaintiff's recovery to nominal damages.’
If the action is brought for a breach occasioned by an in-
cumbrance, the defendant may show that the grantee agreed
to assume and pay off such incumbrances as a part of the con-
sideration for the land, and he may introduce parol evidence to
show the agreement between him and the grantee in regard to
the matter.*
$2 Duer (N. C.) L. 304 Id. 46, general notes.
Where land has been conveyed with covenant of warranty and it
has passed by a subsequent conveyance through the hands of
various covenantees, the last covenantee or assignee in whose possession
the land was when the covenant was broken, has a right of action against
any or all of the prior warrantors, whether immediate or remote for a
breach of the covenant. Prescott v. Hobbs, 30 Me. 345; Mills v. Catlin
22 Vt. 98.
Covenants for Jand broken in the covenantee’s lifetime goes to the
estat>, but those broken after his death to his heirs. Smith v. Hay, 37
B. Monroe (Ky.) 94, 6 T. B. Monroe 40; Grant v. Hodges, 3 Duer (N. C.)
L. 200; Van Rensselear v. Planter, 2 Johns cas 17.
In Connecticut, in an action upon a covenant of seizin, the damages is
the consideration money with interest. Upona covenant of warrantry,
the value of the property at the time of the eviction. Sterling v. Peet,
14 Conn. 246.
-On a technical breach of a covenant of seizin and right to convey, the
grantee can only recover nominal damages. Overhiser v. McCallister, 10
Ind. 41; Nosler v. Hunt, 18 Ia. 212.
+ Pitmanran v. Conner, 27 Ind. 337.
In an action for a breach of seizin the fact that the grantee has been
compelled to pay his own grantee a large sum on his own covenant of
warranty will not enlatge his claim for damages. Nichols v. Walters, 8
Mass. 243.
Where incumbered is conveyed with covenant of warranty, and free-
dom from incumbrance is changed into a title adverse and indefeasible,
the measure of damages is the consideration with interest. Jenks v.
Hopkins, 8 Pick. 346.
'
CHAPTER XXVIII.
COVENANTS—REAL ESTATE.
Executor CONTRACT FOR THE SALE oF LAND. THE GENERAL
RULE OF DAMAGES WHERE THE VENDOR ACTS IN GOOD FAITH.
RULE OF DAMAGES WHEN THE VENDOR ACTS IN BAD FAITH.
PuMPELLY Vv. PHELPS, SUBSEQUENT CASE. THE RULE OF
DAMAGES UNDER CERTAIN DECISIONS. THE ENGLISH AUTHOR-
Irigs. Worrau v. Munn. Hapiey v. BAXENDALE. Hop-
KINS v..LeE. GooD AND BAD FAITH. ADAMSON V. ROSE.
RULE OF DAMAGES IN MAINE. EXCEPTIONS TO THE RULE.
DouEerty v. IsLtAND. DAMAGES IN CASE OF BREACH OF
VENDEE. DAMAGES WHERE THE DEED Is TENDERED. PRox-
IMATE DAMAGES CAN ONLY BE RECOVERED. THE TRUE RULE.
RECISION OF THE CONTRACT. LAWS.
421. Executory Contract for the Sale of Land. In this coun-
try, where land is constantly chonging hands, controversies:
frequently arise on breaches of coatract for the sale and trans-
fer of it. It, therefore, becomes a matter of importance
to have the rules for the assessment of damages clearly
defined. And it is to be regretted that the authorities are not
uniform upon the question, and in 'many cases are in direct
REAL ESTATE. 361
conflict. In England, and in perhaps, the majority of the
States, it is held that the measure of damages in case of a
breach by the vendor should be. the same as on a breach of
covenant of warranty or title, which is held to be the purchase
money with interest.! While in other States it is claimed
that the rule for the assessment of damages in case of a breach
of contract to deliver goods, where the consideration has been
fully paid, which is the highest value of the property up to
the time of bringing the suit, should be the amount of the re-
covery.”
422. The General Rule Where the Vendor Acts in Good Faith.
We think, however, that where the vendor makes his contract
of sale in good faith and is for any reason unable to make the
conveyance and is guilty of no fraud, thatthe clear weight of
authority is that the vendee is limited in his recovery to the
consideration money, with interest, with, perhaps, in addition,
the costs of investigating the title.’
’ Hammon y. Hannin, 21 Mich. 374.
2? Hammon y. Hannin, supra.
3 Hammon v. Hannin, 31 Mich. 374; Walker v. Moore, 10 B. Monroe -
and C. 416; Sikes v. Wild, 1 B Monroe and S. 587; same cov. 4 id. 421;
Baldwin v. Munn, 2 Wend. 399; Peter v. McKeon, 4 Denio 546; Conger
v. Weaver, 20 N. Y. 141; Allen v. Anderson, 2 Bibb. 415; Gaff v. Hawks,
5 J.J. Marsh 341; Combs v. Tarlton, adm , 2 Dana 464; Seamore v. Har-
land, 3 Dana 410; Hendon v. Venable, 7 Dana 371; Hall v. Delaplaine, 5
Wis. 206; Fold v. McKingan, 4 Iowa 1; Sween v. Steele, 5 Iowa 3852;
Blackwell v. Lawrence Co., 3 Black 143; Thompson v. Guthrie, 9 Leigh
101; Loomis v. Waibams, 8 Gray 557; Dunica v. Sharp, 7 Mo. 71; Mc-
Clowry v. Crogham, 31 Pa. st. 22; Dunmars v. Miller, 34 id. 150; Adam-
son v. Rose, 30 Ind. 380.
The rule is well settled that where a vendor enters into a contract to
sell and convey real estate under a belief that he has a good title and
that the same is free from incumbrance, with covenant of warranty and
against such incumbrauce, and he fails to perform for the reason that the
title is defective or an incumbrance unknown to him rreviously is dis-
covered, which prevents a fullfillment of the contract in an action by the
vendeé against him for a breach of the contract, the latter is only liable
for nominal damages. Cockcroft v. N. Y. & H. R. R. Co., 69 N.Y. 201;
362 LAW OF DAMAGES.
423. Where the Vendor Acts in Bad Faith. There are also
numerous cases which decide that if the vendor acts in bad
faith, as if having title he refuses to convey or disables him-
self from conveying, the proper measure of damages is the
value of the land at the time of the breach, the rule in such
case being the same in relation to real as to personal property.’
Pumpelly v. Phelps, 40 N. Y. 562; 24 Barber 100; 43 Barber 469; Conger
v. Weaver, 20 N. Y. 144; Legget v. Mutual Life Ins. Co., 53 N. Y. 394.
One very strong reason for limiting the recovery to the consideration
money and interest in case it is free from bad faith, is that the measure
of damages is thus made to conform to the rule where the party assumes
to convey land which he does not own. and an action is brought against
him on a covenant of title in his deed. This reason is made specially
prominent in many of the cases, and it cannot be denied that it is an
anomaly if the vendee is restricted to the recovery of on° sum when an
effectual deed is given, but allowed to recover a larger compensation in
case the vendor, when he discovers the defect in his title. has manliness
to inform the vendee of the fact and decline to execute worthless paper.
Hammon v. Hannin, 21 Mich. 374.
These contracts are merely upon the condition frequently expressed,
_ but always implied, that the vendor hasa good title. Ifhe has not, the
return of the deposit with interést and costs is all that can be expected.
Flurreau v. Thornhill, 2 W. Bl. 1078; Sedgwick’s leading cases on the
measure of damages, 3.
It seems, therefore, more reasonable to treat the mere contract for
the conveyance of land not as based upon an implied warranty that the.
vendor has power to convey, but as involving the condition that the
vendor has a good title, and that if, on examination of the abstract, this
turns out not to be so, the vendee cannot ask to be put in as good con-
dition as if the conveyance with usual covenants of warranty had been
executed but can only recover the expenses to which he has been put.
All that has been hitherto said leads to the conclusion that the case of
Flurreau v. Thornhill was rightly decided. Bain \. Fothergill, L. R. 7
Eng. & Ir. App. 158; 43 L. J. N. 8. Exch, 243; 31 L. J N.S. 387.
4 McConnell heirs v. Dunlap, Hardin 41; Gerault v. Anderson, 2 Bibb.
543; Davis v. Lewis, 4 Bibb, 456; Driggs v. Dwight. 17 Wend. 71; Dustin
v. Newcomer, 8 Ohio 49; Adams v. McMullen, 7 Porter 72; Trull v.
Granger, 8 N.Y. 115; Martin v. Wright, 21 Ga. 504; Cox v. Henry, 32
Pa. st. 18.
It is claimed that the damages are excessive; that the most to which
Wolcott is entitled under the facts is the money paid and expended by
him, with interest. It will be noticed that there had been no improve-
ments made on the land by Wolcott, except such as were contemplated
REAL ESTATE. 363
424. In the case of Pumpelly v. Phelps, where a trustee
_ authorized to convey land only on obtaining a written consent
of his cestui que trust, contracted in his own name to sell with-
out having obtained such written consent, although he at the
time, in good faith, expected to be able to procure it, and af-
terwards, on account of the refusal of the cestui que trust to give
the written consent, was unable to give a title, it was held by
the majority of the Court of Appeals of New York that the
purchaser was entitled to recover of the vendor the difference
between the contract price of the land and the value at the
time of the breach.* F
425. But in a subsequent case, a widow, having only a
dower right in a lot of land, the title to which was in her chil-
dren, three of whom were infants, contracted to sell the lot to
the plaintiff for alittle more than the third of the actual
value, of which she was ignorant, while the plaintiff was
aware of it. Before the making of the contract the lot had
been sold for taxes and a lease of it given pursuant to the sale.
These facts the widow was ignorant of, but they were known
to the purchaser, who also knew that the widow. could only
convey by judicial authority. This, of course, would not be
given unless the actual value was concealed from the court.
These features were held to distinguish the case from that of
Pumpelly v. Phelps, noticed in the preceding section, and it
was held that the plaintiff was entitled to recover not the dif-
by the contract itself. Case, by his own wrongful act after part per-
formance, had put it out of the power of Wolcott to comply with its pro-
visions In such case we think that the measure of damages is the dif-
ference between the unpaid purchase money and the actual value of the
land at the time of the breach. This would place the parties in the con-
dition they were in at the time of the breach. Case v. Wolcott, 33 Ind. 5.
5 40 N. Y. 59; Cockcroft v. the N. Y. & H.R. R. Co., 69 N. Y. 201; 24
Barber 100; 43 Barber 469; Conger v Weaver, 20 N. Y. 144; Leggett v.
Mutual Life Ins. Co. 53 N. Y. 394; Peter v. McKeon, 4 Den. 546; Bald-
win v. Munn, 2 Wend. 399.
364 LAW OF DAMAGES.
ference between the contract price and the value of the land,
but only so much of the purchase money as had been paid with _
interest.°
426. The Rule Under these Decisions. It may be laid down
as a general rule that a party who, under a wrong impression,
and without knowledge of the existence of any defect in his
title, or of any incumbrance upon his land, and who is inno-
cent of any intention to commit fraud, enters into a contract
which it subsequently appears he is unable to perform, can
only be held liable for nominal damages, besides the amount of
the purchase money which has been paid upon the same with
interest.’ This rule rests upon a want of knowledge and good
faith of the vendor, and so long as these elements appear in
the transaction it matters not whether the title is imperfect
in itself or is rendered defective by reason of the incumbrance
on the land, for where such inctimbrance exists there is a
defect of title so that a deed cannot be executed which will
eonvey a good title, and the rule applies.
427. The English Authority. The rule laid down by the
English courts is in harmony with the one we have been con-
sidering, that where the owner of real estate finds unexpectedly
difficulties in making out his title, which he cannot overcome,
and the opposite party rejects the title and repudiates the
contract, it is not unreasonable that he should be entitled to
® Margraf v. Muir, 57 N. Y. 159.
" Cockcroft v. N. Y. & H. R. R. Co., 69 N. Y. 201.
' Cockcroft v. N. Y. & H. R. R. Co., 69 N. Y. 201.
In case of an agreement to convey land or exchange land, and one of
the parties knew at the time that he had no title to the land which he
agreed to convey, in an action against him by the other party to recover
damages for a failure to convey, the extent of the recovery should be
measured by the value of the land to be conveyed to the plaintiff.
Plumer v. Higdon, 78 Ill. 222. :
REAL ESTATE. 365
no more than the return of the deposit and the expense of in-
vestigating the title.
428. Worral.v. Munn. The Court of Appeals in the State
of New York in this case, which was a suit brought by a ven-
dee against the vendor for refusing to convey according to con-
tract a certain tract of land, in commentary on the question of
damages said: “The rule declared by this court on the former
appeal that the plaintiff was entitled to the interest on the
purchase money paid by him as damages for being kept out of
possession, was supported by reason and authority. * * *
It is supposed, however, by the counsel for the defendant that
the additional facts claimed by him to have been shown on the
hearing before the referee, viz.: that no profitable use could
have been made of the premises for brick making purposes
during the retention of the possession by the defendant, and
that, in fact, no use was made of them for that purpose by the
plaintiff for several years after he obtained possession, and that
the premises meanwhile advanced in value, change the legal
aspect of the case, and required that the damages for with-
holding the possession be limited to the rental value of the
land for ordinary use, as the plaintiff lost nothing beyond that
of being deprived of possession. I think this view procecds
upon a misconception of the privilege upon which the courts
’ of equity adjust the right of the vendor and the vendee, where
the vendor retains the possession of the land and refuses to de-
liver it according to the contract. If the purchase money has
not been paid, the vendee may elect either to pay the interest
on the purchase money during the time he has been wrong-
fully deprived of the possession and take the rents and profits
received, or which might have been received by the vendor
* Engle v. Fitch, 3 L. R. 2 B. 314; see Mack v. Patchin, 42 N. Y. 167;
Cockcroft v. N. Y. & H. R. R, 69 N. Y. 201; Bain v. Fothergill, 43 L. J.
Ez. 243; 10 Barn & Cress 416; Buckly v. Dawson, 4Irish C. L. N. 8. 211.-
366 LAW OF DAMAGES.
4a
during the same time, or he may allow the vendee to retain
the rents and profits, in which case he will be exempt from
the payment of interest. It is not because the rental value of
the land is, or is supposed to be, equal to the interest on the
purchase money that the right of electionis given. It is often,
perhaps, in most cases less, but the enjoyment of the posses-
sion of the land, according to the contract, may be more valua-
ble to the purchaser, or he may regard it of more value to him,
than the amount of rents and profits he might realize from the
/ use. The possession of the premises by the purchaser is by
the contract of sale treated as of equal value to him as the in-
terest on the purchase money, and when the vendor wrong-
fully refuses to give possession and resists, the performance of
the agreement, he ought not to be allowed to reap the benefit
of the contract and compel the vendee to pay interest on the
purchase money, if it turns out that the interest exceeds the
rental value of the land. In thiscase the purchase money was
paid some years before the plaintiff was let into possession, but
the rule is not changed by that fact. The purchaser is entitled
to be allowed interest on the purchase money. The advantage
to the vendee from the appreciation in the value of the land
was incident to his right as purchaser, and if it had fallen in
value the loss must have been borne by him.”* |
429. Hadley +. Baxendale. The rule for the assessment of
damages in case of a breach of contract as laid down in this case,
is, perhaps, as free from objection as any rule can be laid down in
such cases. It is this: ‘ Where two parties have madea con-
tract, which one of them has broken, the damage which the
other party ought to receive in respect of such breach of con-
tract, should be such as may fairly and reascnably be considered
either arising naturally, that is according to the usual course
363 .N. Y. 185.
REAL ESTATE. 367
of things, from such breach of contract itself or such as may
reasonably be supposed to have been in the contemplation of
both parties at the time they made the contract, as the proba-
ble result of the breach of it applies.”
Thus, when after a part performance by the vendee of a
contract for the conveyance of real estate under an agreement
that the vendee should pay a certain amount of money per an-
num, and on failure was to forfeit the whole land, the vendor,
before the vendee had made any defaults in the payment of the
stipulated amouut, declared the contract at an end, and pre-
vented the vendee from fully complying with the contract.
The vendee put such improvements on the land as was con-
templated by the contract itself, In an action by him for
damages it was held that the measure of damages was the dif-
ference between the unpaid purchase money and the actual
value of the land at the time of the breach.
430. Hopkins v. Lee. In this case the court said: “The
rule is settled in this court that in an action by the vendee for
a breach of contract on the part of the vendor for not deliver-
ing the article, the measure of damages is the price at the
time of the breach. The price being settled by the contract,
which is generally the case, makes no difference, nor ought it
to make any, otherwise the vendor, if the article has risen in
value, would always have it in his power to discharge himself
from his contract and put the enhanced value in his own
pocket, nor can it make any difference in principle whether
the contract be for real or personal property, if land, as is the
case here, have not been improved or built on. In both cases
the vendee is entitled to have the thing agreed for at the con-
4 9 Exchequor 341.
5 Case v. Walcott 33 Ind. 5.
» ence.
368 LAW OF DAMAGES.
tract price and to sell it himself at its increased value. If it be
withheld, the owner ought to make good to him the differ-
26
431.' Good and Bad Faith. The distinction made between
good and bad faith in the grantor is now almost universally
recognized. In the case of Kirkpatrick v. Dunning, the Su-
preme Court of the State of Missouri reviewed the authorities
bearing upon the question, and held the “general rule to be
that where the failure or inability to convey is owing to the
fault of the vendor, the vendee is entitled to the value of the
property at the time of the breach, provided the consideration
has been paid, and that even where the consideration has not
been paid or tendered, if the vendor has placed it out of his
power to convey, the vendee may recover the difference be-
tween the contract and any increased value of the land beyond
such price.” They said: “The rule must be reciprocal, that
where the property has enhanced in value the purchaser gets
the benefit of the enhancement. So, where a depreciation has
taken place, he must submit to a corresponding loss. In both
cases he obtains the true measure of damages, full compensa-
tion for the loss sustained. Where there is no evidence given
showing any change in the situation, the consideration paid
and interest will be taken as the correct value of the land, but
where there is evidence given showing a change in the value
of the land, the value at the time the breach occurred and when
the conveyance ought to be made will furnish the standard of
damages. This is fair and just for both parties, as they obtain
precisely what they are entitled to, and the basis is predicated
on the full and actual loss.”
432. Adamson v. Rose. The Supreme Court of Indiana in
°6 Wheat U.S. 109.
758 Mo. 32; see 78 Ill. 222.
REAL ESTATE. 369
this case, which was brought by the plaintiff to recover dam-
ages on a breach of a title bond to convey a certain tract of
land with a steam saw mill situated thereon, the plaintiff
averred that the purchase money had long since been paid to
the defendant; that at the time he purchased the land he did
it with the expressed view of getting the saw mill to be situ-
ated upon the land, all of which the defendant well knew;
whereas, the saw mill was situated upon land to which the de-
fendant had no title. The consideration was paid by the
plaintiff in money and the consequence of land and other
property to the defendant, which was received by the defen-
dant in full satisfaction of the price agreed upon for the land
by the parties. The court held that the payment of anything
else than money was ‘by a subsequent agreement of the par-
ties. The acceptance of the property in accord and satisfaction
bound the defendant tu the fulfillment of his contract to the
same extent as if payment had been made in money. The
measure of damages in such case is the purchase money and
interest.
433. Rule in Maine. Ina late case in the State of Maine,
which was an action for damages for the breach of an agree-
ment to convey land, it was held: 1. That the plaintiff's
damages were to be measured by the value of the land at the
date of the breach. 2. That the rule was not varied because
the defendant, though acting in good faith, was unable to con-
vey. 38. That the plaintiff at his election, in case of a total
failure to convey, might rescind the contract and recover so
much of the consideration as had been paid with interest.’
434. Exception to the Rule we have been Considering. There is
quite a number of decisions that ignore the good or bad faith
130 Ind. 380; see also Blackwell v. Board of Justices, 2 Blackford 1438.
? Doherty v. Doland, 65 Maine, 87.
370 LAW OF DAMAGES.
of the vendor, and hold that if he had no title to the land he
agreed to convey, and an action is brought against him by the
vendee to recover damages for a failure to convey, the extent
of the recovery should be measured by the value of the land to
be conveyed to the plaintiff. That the covenant requires the
conveyance to be made at a future day. If the land rises in
value it is the right of the purchaser to receive the conveyance
of it in its increased or diminished condition on the day agreed
upon in the contract.’
435. Damages in Case of Failure of the Vendee. The general
rule of damages on a failure of the vendee to receive a convey-
ance to the property purchased and pay for the same would be
full compensation jor all loss sustained by the vendor thereby,
which, as « general rule, is the difference between the contract
price and the actual value of the land.at the time of the breach,
if the property shall have declined in value.’
436. Damage When a Deed has been Tendered. It may be laid
down as a general rule, supported by the weight of authority,
that where a grantor has tendered a deed to the grantee, which
he has refused, the vendor may recover the price agreed to be
paid, with interest. But in order to recover this sum he must
keep his tender good.
* Plumer v. Regdon, 78 Ill. 222; Hill v. Holbert, 16 Me. 164; Hopkins
v. Lee, 6 Wheat 109; Drake v. Baker, 34 N. J. 358; Lawrence v. Chase,
54 Me. 194; Boardman v. Keeler, 21 Vt. 84; Kirkpatrick v. Downing, 58
Mo; 32; Barnham v. Nichols, 3 R. 1. 187; Wellsv. Aberthany, 5 Conn 222.
5 Old Colony Road Co. v. Evans, 6 Gray 25; Laird v. Pim, 7 Mers. & W.
474; Hopkins v. Lee, 1 Curtis U. 8. R. 266;6 Wheat 109; Morgan v.
Wood, 33 Ind. 5; Doherty v. Dolan, 65 Maine 87; Pumpelly v. Phelps, 40
N. Y. 759; Paper v. Fravin, 40 Ind. 556.
* Field on the law of damages, Sec. 509; Franchot v. Leach, 5 com. 506;
Sadon v. Comstock, 21 Wend. 457; Alna v. Plumer, 4 Me. 258; Marshall
vy. Harney, 4 Md. 498; 9 Ia. 194; Whiteside v. J ennings, 19 Ala. 784;
Goodpasture v. Porter & Courtney, 11 Ia. 161; Goodson v. Nunn, 4 T. R.
REAL ESTATE. 371
437. Damages Where the Deed is Tendered Discussed. The
rule in case of the sale of personal property is well established
that if the purchaser tenders the purchase money and offers to
perform the contract under certain circumstances the title to
the property will vest in him. The question as to whether
the same rule applies in case of the sale of real estate by a ven-
dor and a tender of a deed by him to the purchaser is not well set-
tled. We are, however, much inclined to the opinion that the
rule cannot be made applicable to the sale of real estate, which
can only be transferred by deed. The rule is pretty generally
settled that in an action against the vendee who contracts for the
purchase of real estate at a stipulated price and subsequently
refuses to perform his contract, the loss in the bargain consti-
tutes the measure of damages, and that is the difference between
the price fixed in the contract and the saleable value of the land
at the time the contract was to be executed, and it seems to us
this should be the rule whether the deed was tendered
or not. This is in harmony with the general rule of full
compensation for all losses sustained, and leaves the parties
in status quo. Thus, the Supreme Court in the State of
Massachusetts, after reviewing the authorities, says:
“Upon a more full consideration of the question of the
measure of damages in an action at law, where the de-
fendant has refused to receive the deed tendered him, the
court is of opinion that the proper rule of damages in such
case is the difterence between the price agreed to be paid for
the land and the saleable value of the land at the time the con-
tract was broken.’”
438. The Proximate Coneequence of the Breach. It is doubtless
761; Glazebrook v. Woodson, 8 T. R. 366;. Sanburn v.- Chamberlain, 101
Mass. 409.
7 Old Colony R. R. Co. v. Evans, 6 Gray (72 Mass.) 25.
372 LAW OF DAMAGES.
true that in all actions for a breach of contract, the loss or in-
jury for which damages are sought to be recovered must be a
proximate consequence of the breach. A remote or possible
loss is not sufficient ground for compensation. There is no
measure for those losses which have no direct and necessary
connection with the stipulations of the contract or which are
dependent upon contingency other than the performance of
the contract, and which are, therefore, incapable of being esti-
mated. With no certainty can it be said that such losses are
attributed to the wrongful act or omission of him who hus vio-
lated his engagement. The different rules that we have no-
ticed in this chapter have the same object in view, that is to
give the injured party all the proximate damages resulting
from the breach, and the different methods adopted for the as-
sessment of damages are only different means for the accom-
plishment of the same object.®
439. The True Rule. After examining the authorities
upon the question of the measure of damages in case of a breach
of covenant to convey land, we are not fully satisfied with the
rule that draws a distinction between good and bad faith. The
object of the law is to restore to the injured party what he has
lost by the breach of contract by the delinquent party. In
such case the damages can be easily estimated by a mathe-
matical calculation, and are not left to the discretion of a jury.
And in case of a breach the injury to the plaintiff will be just
the same whether the defendant acted in good or bad faith in
making the contract. The object of the law is to render to each
person his just dues, and where one has been damaged by the
conduct of another to take from the wrong-doer a sufficient
amount of property and give it to the injured party as will
place him in as good condition as he was before he received the
injury. And this rule should be adhered to whether the
* Adams Express Co..v. Egbert, 36 Penn, st. 360.
REAL ESTATE. 373
wrong-doer acted in good or bad faith. As we have already
said, in discussing the question of exemplary damages, the
civil and criminal practice should be kept separate and apart
as far as possible. And in the assessment of damages for a
breach of civil contract the motives that actuated the delin-
quent party in making the breach should not be considered in
estimating the damages. It is only where the motives or bad
intentions enter intoand form an element in inflicting the inju-
ry complained of that they should be considered in estimating
the damages. We think, therefore, that the true rule in all
such cases is the actual damages sustained, or full compensa-
tion for the injury received. This suggestion is, we think, in
conflict with the weight of the most recent authorites.
440. A Rescission of the Contract. As we remarked in our
comments on a rescission of contract on account of fraud, a party
who has been defrauded has one or two remedies. He may
tender back the consideration received and rescind the contract
or he may retain the consideration and sue for damages. But
a purchaser who has given notes for the purchase money and
taken possession of the land cannot rescind the agreement and
resist the payment of the notes so long as he remains in pos-
session, and he must be prompt in making his application for
recision after he discovers the fraud, or he will confirm the
contract.
441. Lease. The general principle of full compensation
for all losses that we have already considered is applicable
to a breach of contract of a lease, and we only intend to notice
the subject in a brief manner. Thus, in an action to recover
damages for a failure on the part of the landlord to comply
with the conditions of a lease of a grist mill in failing to keep
1 See chapter on fraud.
874 LAW OF DAMAGES.
in repair a mill dam, by reason of which failure the tenant
was without the necessary supply of water to do his business,
the measure of damages was held to be the difference between
the rental value of the mill in the condition that it was in and
its value if it had been kept in the condition stipulated by the
landlord.?
* Wenne v. Kelly, 34 Ia. 339; see post chapter Landlord and Tenant.
CHAPTER XXIX.
LANDLORD AND TENANT.
THe Hiring or Reat Property. Tur LANDLORD NEED NOT
RENEW THE LEASE. DAMAGES FOR FAILURE TO MAKE RE-
PAIRS. GENERAL RULE IS ACTUAL DAMAGE. HADLEY Vv.
BAXENDALE. THE POWER OF THE LANDLORD. AN ACGREE-
MENT TO REPAIR. FIxTuREs. THE DAMAGES. WASTE.
442. The Hiring of Real Property. The hiring of real
property is usually effected by means of a lease which is a con-
tract, whereby the landlord or owner of the land agrees with
the tenant that he (the tenant) may occupy his premises for
a certain consideration. The agreement is termed a lease.
The leasing of land carries with it all proper appurtenances
and accompaniments which are needed for the proper use and
enjoyment of the premises.*
443, The Liability of the Landlord. “There is an implied.
covenant on the part of the landlord to put the tenant into
* Morris v. Saunt, 24 Taunt, 31; Rogstray v. Lucas, 5 B. & L. 830; Hard-
ing v. Wilson, 3 B. & C. 96.
376 LAW OF DAMAGES.
possession, and that he shall quietly enjoy.” ‘Anda covenant
for quiet enjoyment is implied in every mutual contract for
leasing and demising of land by whatever form of words the
agreement is made.®
But there is no implied warranty on his part that the
premises shall be reasonably fit for habitation, occupation or
cultivation.’ He is under no legal obligation to repair unless
there is a stipulation in the lease that he shall do so.'
443. The Landlord is Under no Obligations to Renew the Lease.
He is not bound to renew without an expressed covenant, and
such covenants are not favored if they tend to perpetuity, but
where they are definite and reasonable the law will sustain
them.’
444, The Measure of Damages. The lessee in case he has
been prevented by a breach from entering the premises under
his lease, is entitled to recover from the lessor the value of the
lease. If he has entered and been evicted, he may recover the
value of the lease for the unexpired term.’
i
51 Parson on contract, 422.
§ Mack v. Patchin, 42 N. Y. 167; 1 Am. R. 506; Smith, Landlord and
Tenant, 206; Taylor, Landlord and Tenant, Sec. 302; Mayor v. Maline, 3
Kernan 160; 11 Page 566; Tone v. Brorce, 8 N. Y. 307: Vernon vy. Smith,
15 N. Y. 328; Groves v. Burdone, 26 N. Y. 498; Sedgwick on measure of
damages, 185°
"Estep v. Estep, 23 Ind. 114; Hart v. Windsor, 12 Mees. & Wels. 68.
" Bedall v, Reed, 33 Ind. 529; Erie Canal v. Brett, 25 Ind. 409; Womack
v. McQuay, 28 Ind. 103; Kellenberger v. Forman, 25 Ind. 409; 1 Parson
on contract, 428; Arden y. Pullen, 10 M. & W. 321; Hart v. Windsor, 12
Ia. 68; Izon v. Gorton, 5 Bing. N. C. 501; Moffat v. Smith, 4 Comst. 126.
* Furmical v. Crum, 3 Ark. 883; Cook v. Booth, Cowp. 819; Williams v.
Williams, 16 Vt. 72-84; Sadlie v. Biggs, 27 E. L. & E. 74; 1 Parson on con-
tract, p. 422.
1 Mack v. Patchin,
42 N. Y. 167; Lock v. Fiezer, 14 W. R. 403; 15 L. J.
N.S. 161; 19C. B. N. 96; 34 L. J
J.C. P. N. 201.
LANDLORD AND TENANT. 377
445. Damages for Failure to Make Repairs. In case of a
breach of a covenant to make repairs, the Court of Appeals of
the State of New York in a recent case where the defendant
leased the plaintiff a hotel and certain adjoining premises in
the city of New York, covenanting to tear down the old build-
ing on the adjoining premises and erect in place of it a new
one to form a part of the hotel, and also covenanting to put the
plaintiff in possession of it by a specified time.” The plaintiff
was then occupying the hotel and building on a portion of the
adjoining premises under a former lease. He removed his fur-
niture and stored it while the new building was in process of
construction. In an action brought to recover damages for the
defendant’s breach of agreement to complete the new building
within the specified time, the court held that the plaintiff
could recover the value of the use for hotel purposes of the
rooms in the new building during the time he was deprived of
the use of them by the defendant’s default, and as to such of
them as the plaintiff had furniture for he was entitled to the
value of their use as furnished rooms. The court also held
that the plaintiff could have made the repairs, in case the de-
fendant failed to do so, and charged the expense to the defen-
dant. That the plaintiff was entitled to recover for the use of
all or any part of the premises made untenable by the defen-
dant’s neglect.’
446. Damages for Failing to Keep a Gatein Repair. In the
case of Beach v. Crain, the plaintiff leased of the defendant a
certain strip of grotind for a right of way, and agreed to erect a
gate at the terminus. The defendant was to keep it in repair.
The tenant erected the gate, but the landlord failed to keep it
in repair. The tenant brought suit for to recover damages on
” Hexter v. Knox, 63 N. Y. 561; Mack v. Patchin, 42 N. Y. 167; Tuell
v. Granger, 4 Seld. 115; Tracy v- A. B. Exchange Co., 3 Seld. 475; Myers
v. Burns, 35 N. Y. 272; Myers v. Burns, 33 Barber 401.
378 LAW OF DAMAGES, |
the breach. The court held that the covenant was a con-
tinuous one, and that the fact that the plaintiff had recovered
for a former: breach was no bar to his recover in that case. It
also held that the measure of damages was not the costs of
making the repairs, but the actual injury that the plaintiff
had sustained by the breach of the covenant.’
447. In Pennsylvania where the defendant let a frame
building weatherboarded in front and behind, but the sides
were stud partition lathed and plastered. Along side of it was
a brick building built entirely on another lot, owned by an-
other person, which, while it stood, fully protected the house
occupied by the plaintiff. The owner of the brick building
removed it, as he had a perfect right to do and the defendant
could not have prevented him. The original frame partition
of the house occupied by the plaintiff was an insufficient pro-
tection from the weather, in consequence of which the plain-
tiff’s goods and chattles suffered injury. The court held that
there was no breach of the covenant in the lease for quiet en-
joyment, and that the plaintiff could not recover.‘
448, Where a tenant occupies the lower portion ofa house
and another tenant the upper portion, and the roof of the house
is destroyed by fire and the landlord fails to make the necessary
repairs, or to re-roof the house by reason of which the tenants’
property in the lower portion is injured, there being no cov-
enant in the lease that the landlord shall repair, the tenant
can n@t recover damages.°
32N. Y. 86.
* Moore v. Weber, 71 Pa. st. R. 429; 10 Am. Report 708.
In an action by the plaintiff to recover damages for overflowing his
land, it appeared that the defendant had for many years overflowed the
plaintiffs land, paying him therefor. The court held that the relation of
landlord and tenant was created, and that there could be no recovery
beyond the amount of yearly rent without notice. Morrill v. Mackman
24 Mich. 279. ;
5 Doupe v. Cenin, 45 N. Y. 119.
LANDLORD AND TENANT. 3879
449. But in an action by the tenant for damages on ac-
count of eviction by a landlord of his tenant from the leased
premises before the expiration of the leases, the jury should in
assessing damages take into consideration the imprdveme.its
the tenant has made upon the premises before expulsion,
which render them more productive.’ The plaintiff can re-
cover on such cases all damages arising ditectly from the
breach, but not remote or special damages, such as expense for
moving to a more remote farm.’ But after the consummation
of the contract to lease the premises the landlord refuse to let
the tenant into possession, and the tenant brings suit to re-
cover damages for being kept out of possession, he can recover
only sueh a sum as will make him whole, which is generally
the value of the premises for the term, with the rent reserved,
including such damages as arise naturally and directly out of
the breach. He may, however, recover special damages caused
by the breach of the contract, as loss of employment and ex-
pense incurred in preparation for a removal to the premises.”
450. In California the plaintiff leased of the defendant a
water lot in San Francisco. The lease contained the usual
clause in regard to time and payment of rent, etc., in the cus-
tomary form, except that it contained a special covenant in
the following words: ‘“ And the said party of the first part doth
hereby covenant and agree to and with the party of the second
part that he will well and truly erect or cause to be erected
upon said premises within two months from the date of this
lease a building according to certain plans and specifications.
This day agreed to and signed by the said parties. And the
said party of the second part doth hereby covengnt and agree
for himself, his executors, administrators and assigns that he -
5 Ricketts v. Lostetter, 19 Ind. 125.
6 Williams v. Obphian, 3 Ind. 271; Adair v. Bagley, 20 Iowa 238.
1 Adair v. Bagley, 20 Iowa 238; Sedgwick on the measure of dam., 227.
380 LAW OF DAMAGES.
and they shall well and truly keep the said building so to be
erected as aforesaid in good repair during the said term hereby
granted.” The defendant erected the building and the plain-
tiff took possession and paid the rent to June following. About
that time the building was destroyed by fire. The court held
in an action by the lessee to recover damages from the lessor
for failing to rebuild, that he could not recover; that the lessor
was not bound to erect a new building on the premises, and
that the fact that the lessor failed to rebuild did not relieve the
lessee from his obligation to pay rent.’ In an action brought
in one of the counties in the State of Wisconsin by a lessee
against a lessor for a breach of a covenant to repair a saw mill,
the Supreme Court held that the plaintiff could recover dam-
ages for the time that he was unable to use the mill on that
account and all necessary expense incurred in hauling his logs,
then in his yard, to another mill to be sawed, which might
have been sawed by them during the term had the mill been
in repair.’ 3
451. Where a landlord leased his mill to a tenant on the
condition that the lessee should pay him two-thirds of the gross
earnings of the mill and to bear all expenses of running the
same, he was ousted by the lessor before the expiration of the
term. The lessee brought suit for damages occasioned by the
breach. Held, that he could recover one-third of the gross
earnings of the mill during the landlord’s occupation of it,
minus the expense of running.’
1 Connell v. Lumby, 39 Cal. 151; 2 Am. R. 480.
* Hinkly v. Beckwith, 13 Wis. 31; same, 17 Wis. 413.
* Holmes v. Davis, 19 N. Y. 488.
The lessor of a hotel covenanted that an adjoining building owned by
him should not be used for hotel or similar purposes. In an action for
a breach of covenant, the measure of damages is the plaintift’s loss of
profits on the customers who left him in consequence of the breach. L.
Am. 239; Smith v. Theelen, 17.
In an action for a breach of a contract for letting, the measure of dam-
LANDLORD AND TENANT. 381
-452. The General Rule. It may be laid down as a general
rule, to which there are but few exceptions, that the lessee -in
case of eviction should recover the actual damages sustained
thereby.’
453. In the State of Illinois an action was brought by a
tenant against his landlord for damages resulting to the former
for false and fraudulent representation made by the landlord
that he was the owner of certain premises. The tenant relying
on such representation leased the same from the defendant and
erected a shop and machinery on them. He was evicted
under a paramount title and was compelled to remove his
building and machinery from the premises. Held, that the
plaintiff could recover the necessary expense of removing his
shop and machinery to another lot, and the rent of another lot
for the term, simularly situated and of equal rental value, of
the one from which the plaintiff had been evicted.
454, The law is well settled that where a person under-
takes gratuitously to perform work for another that requires
the exercise of care and skill, that he will be held responsible
in damages for all injuries arising for a failure to exercise or-
ages is the difference between the yearly value and the rent received.
Dean v. Roseler; 1 Hilt. (N. Y.)
5 Field on damages, 423.
In Missouri, where the landlord withheld possession from the tenant,
who had been a non-resident of the State, but had removed to that State
for the purpose of occupying the premises, it was held that the measure
of damages would be the difference in the rent, as provided for in the
lease and the rental value of the premises. Hughes v. Hood, 50 Mo. 350
In Pennsylvania the Supreme Court held, in an action for a breach of
contract to lease to the plaintiff a dye shop and furnish him with work,
he having put in fixtures, that the measure of damages was the value of
the bargain. Guased v. Turner, 71 Pa. st. 56.
7 Wilson v. Raybald, 56 Ill. 417.
382 LAW OF DAMAGES.
dinary care and skill. Hence, where a landlord undertook to
repair an outhouse for his tenant without consideration and
performed the work in so negligent and unskillful manner
that the plaintiff's wife was injured by the floor giving away,
the defendant was held liable in damages.’
455. The Rule inthe Case of Hadley v. Baxendale Applies. Thé
rule in this case that we have so often referred to in this work
applies in case of a breach of covenant in a lease, which is this:
Where two parties have made a contract which one of them
has broken, the damages which the other party ought to re-
‘ceive in respect to such breach of the contract should be either
such as may fairly and reasonably be considered as aris-
ing naturally, that is according to the usual course of things,
from such breach o' contract itself or such as may reasonably
be supposed to have been in contemplation of both parties at
the time they made the contract as the probable result of the
breach of it.*
456. The Power of the Landlord. At the expiration of the
lease the landlord may peaceably enter upon the premises and
turn the tenant out, and his intentions in entering the prem-
ises will make no difference, for if he enters peaceably with a
full determination to evict th» tenant and gains an entrance
without the exercise of such acts of violence as will subject
him to a criminal prosecution the law will justify his conduct.
After he gets possession he can use the same force to expel the
tenant that he could to expel one who had entered his dwelling
? Benden v. Manning, 2 N. H. 289; Thorne v. Dias, 4 Johns 84; Else v.
Gatward, 5 J. R. 148; Shulls v Blackburn, 1 H. Pl. 158; Bafe v. West, 22
E. & L 506; Gill v. Middleton, 105 Mass 477.
? Gill v. Middleton, 105 Mass. 477.
* Johnson v. Arnold, 2 Cush. 46; Denning v Dwight, 17 Wend. 71;
Dean v. White, 5 Ia. 266; Adair v. Bagley, 20 Ia. 238; Field on the law of
dam., 423. ,
LANDLORD AND TENANT. 883
house without authority and refuses to retire when requested.
He may, therefore, retain the possession of his premises by
force, provided no more is employed than becomes :1ecessary to
repel the resistance interposed by the tenant.’
457. The General Liability of the Tenant. The tenant must
‘take possession of the leasehold property at the stipulated
time and perform his part of the contract. He must pay his
rent at the time agreed upon between him and his landlord,
and if there is no time specified when he is to pay his rent it
must be paid according to the general custom of the country.‘
And where no place is designated for the payment of rent, the
law presumes that it was to be paid on the premises. And if
there is a provision in the lease that if the tenant fails to pay
rent he shall forfeit the possession of the premises and the
landlord may re-enter and oust the tenant, and the place of
payment is not designated, the tenant may defeat the land-
lord’s right to re-enter by showing a readiness to pay on the
premises.°
458. Dawson v. Coffman and others, 28 Ind. 220; McGregor v. Brown, 10
N.Y. 117.
* Guinn v. McCatmont, 4 Watts 460; 1 Washburne on Real Property,
109.
" Field on damages, 605-606; Ferguson v. Stafford and others, 33 Ind.
162; McCaslin et al. v. the State ex rel., Auditor of State, 44 Ind. 151.
LANDLORD AND TENANT. 387
assess nominal damages.’ “In an action in the nature of
wastes for cutting down trees on an estate, the, damages are not
confined to the value of the timber removed, but may include
the permanent injury to the estate.’”
111 Met. 304; 28 Ind. 220; Field on dam., 606.
? Harder v. Harder, 26 Barber 409.
CHAPTER XXX.
PROMISSORY NOTES.
Promissory Notes AND BiLts or Excuanes. As A GENERAL
RULE THE DAMAGE IN SUIT ON NOTE 1S THE CONSIDERATION
MONEY AND LEGAL INTEREST. QUESTION AS TO THE PAYMENT
OF A NOTE IN DEPRECIATED CURRENCY DISCUSSED. THE ENG-
LISH RULE. Tur AMERICAN RULE. THE RATE OF INTEREST
FIXED IN THE NOTE WILL BE‘ALLOWED IF NOT FORBIDDEN BY
LAW. WHERE THERE IS NO RATE OF INTEREST STIPULATED
THE HOLDER MAY RECOVER LEGAL INTEREST AFTER MATURITY.
IF NO RATE I8s FIXED BY THE CONTRACT THEN THE HOLDER MAY
RECOVER THE RATE FIXED BY THE LAW OF THE PLACE
WHERE THE CONTRACT IS PAYABLE. INDORSEMENT IN ONE
STATE SENT TO ANOTHER, BY WHAT LAW GOVERNED. NOTE Is
NOT EXECUTED UNTIL DELIVERED. PLACE OF PAYMENT WILL
TO SOME EXTENT FIX THE DAMAGES.
465. Full Compensation. As we have frequently remarked,
the general rule of damages on the breach of a contract, as well
as in tort, is full compensation for the loss sustained or wrong
done. And in case of a suit on a contract for the non-payment
of money, the rule established for the assessment of damages by
the civil as well as the common law is recognized. Causa
proxima non remota spectature is adhered to more strictly than in
a case of tort. The rule laid down in the case of Hadley v.
PROMISSORY NOTES. 389
Baxendale, that we have so frequently referred to in this work
applies, and the plaintiff in an action for the recovery of
money due on contract can only recover such damages as may
fairly and reasonably be considered as “either arising natural-
ly, that is according to the usual course of things, from such
breach of contract itself or such as may reasonably be supposed
to have been in contemplation of both parties at the time they
made the contract as the probable result of the breach of it.”
Remote’ or speculative damages cannot be recovered. This
rule is adopted for the reason that it would be impossible prac-
tically to trace out the remote consequences arising from a
failure to pay money at a stipulated time. Experience shows
that the most fearful consequences sometimes follow from the
failure of an obligor to pay money at the time specified. The
payee frequently’ suffers pecuniary embarrassment by loss of
valuable and profitable contracts and undertakings, loss of
business, reputation, comfort, peace of mind and happiness.
“ And, moreover, it may cause suffering, sickness, insanity and
destroy the social standing not only of himself but his family.”
It would be impossible to investigate such results with any-
thing like accuracy and fix a pecuniary value upon them. The
law, therefore, has limited the plaintifi’s damages to the prin-
cipal, with legal interest, which is looked upon as the proxi-
mate consequence of the breach of the contract. Mr. Pothier,
in the discussion of this question, says: “As the different
damages which may result from a failure to perform this kind
of an obligation vary infinitely, and it is difficult to foresee as
to excuse them, it has been found necessary to regulate them
by a special penalty and_fix them at a precise sum.”
466. The Law Permits the Recovery of Interest. For several
generations men have been both in this country and in Eng- '
’ Pothier on obligations, part 1, ch. 3, 170.
390 LAW OF DAMAGES.
land not only permitted to contract: for a certain rate of in-
terest and enforce the agreement, but, under certain circum-
stances, the law makes the bargain for them, and it may now
be considered a well settled rule that where it is certain that
money ought to have been paid long since, it will be conclu-
sively presumed that the debtor promised to pay legal interest.’
467. Interest on Promissory Notes. As a general rule the
damages that can be recovered in a suit on a promissory note
is the principal and interest, provided it does not exceed the
rate allowed by the law of the state or nation where payable.
And where a note contains no stipulation for the payment of
interest, the holder can generally recover the legal rate from
the time of the maturity of the note until it is paid.®
468. Legal Tender. Questions of the most complicated.
character have frequently arisen in the courts of England and
this country in regard to the payment of promissory notes in a
depreciated currency, where it happened that the shrinkage in
value of the coin or currency occurred after the execution of
the note and before its maturity. The law seems to be well
settled at this time in England that the holder is bound to re-
ceive the money in payment of his note that the government
has seen proper to make a legal tender.’ But in this country
where the rights of the people are hedged in by constitutional
provision and the passages of laws impairing the obligation of
contract prohibited, the question becomes more difficult and
complicated. But our courts have with an unprecedent energy
? Selleck v. French, 1 Conn. 32; Reed v. Resselaer Glass Factory, 3
Com 393; 5 Ia. 587; Doge v. Perkins, 9 Pick. 368; Kennedy v. Barnell, 7.
Rich. 124.
® Field on the law of dam., 193; Edwards on bills and notes, 708 et esq;
U.S Bank v. Chapin, 9 Wend. 471; 19 Johns 246; Owsby v. Greenwood,
18 Me. 429.
"Sedgwick on measure of dam., 282-284, and notes.
PROMISSORY NOTES. 391
examined the question and settled in a definite and satisfactory
manner the authority of the general government to coin money
to issue bills of credit and make them a legal tender. One of
the most important legal questions that perhaps was ever pre-
sented for the consideration of a judicial tribunal, involving
the payment of money, arose under the act of Congress of Feb-
ruary 25, 1862, and other similar acts, making the notes of the
government a legal tender for all debts, both public and private,
(with a few exceptions). The question arose in the case of
Knox vs. Lee, and was discussed with masterly ability and
forensic learning by the Supreme Court of the United States.
The questions discussed in that case are of such magnitude
and importance to the American people, both in a financial
sense and in the way of settling the powers of the government
under the constitution, that we will give it in full in our notes.!
'The controlling questions in this case are the following: Are the
acts of Congress known as the legal tender acts constitutional, when ap-
plied to contracts made before their passage, and, second, are they valid
as applied to debts contracted since their enactments. The question has
been elaborately argued, and they have received from this court that
consideration which their great importance demands. It would be dif-
ficult to. overestimate the consequences that must follow our decision.
They will affect the entire business of the country, and take hold of the
possible continued existence of the government. If it be held by this
court that Congress has no constitutional power, under any circum-
stances or in any emergency, to make treasury notes a legal tender for
the payment of all debts (a power confessedly possessed by every inde-
pendent sovereignty other than the United States), the government is
without those means of self-preservation which, all must admit, may, in
certain contingencies, become indispensable, even if they were not when
the acts of Congress now called in question were enacted It is also
clear that if we hold the acts invalid as applicable to debts incurred, or
transactions which have taken place since their enactment, our decision
must cause throughout the country great business derangement, wide
spread distress, and the rankest injustice. The debts which have been
contracted since February, 25, 1862, constitute, doubtless, by far the
392 LAW OF DAMAGES.
469. The Rate Fixed by the Contract Governs as a General Rule.
The rate of interest fixed by ‘the note or contract will control
if it does not exceed the rate allowed by the law of the place
where the contract was made or is payable.’
1 Lines v. Mack, 19 Ind. 223.
greatest portion of the existing indebtedness of the country. They have
been contracted in view of the acts of Congress declaring treasury notes
a legal tender, and in reliance upon that declaration men have bought
and sold, borrowed and lent, and assumed every variety of obligations,
contemplating that payment might be made with such notes. Indeed,
legal tender treasury notes have become the universal measure of values.
If now by our decision it be established that these debts and obligations
can be discharged only by gold coin; if, contrary to the expectation of
all parties to these contracts, legal tender notes are rendered unavaila-
ble, the government has become an instrument of the grossest injustice.
All debtors are loaded with an obligation it was never contemplated they
should assume; a large percentage is added to every debt, and such
must become the demand for gold to satisfy contracts, that ruinous sacri-
fices, general distress and bankruptcy may be expected. These conse-
quences are too obvious to admit of question. And there is no well—
founded distinction to be made between the constitutional validity of an
act of Congress declaring treasury notes a legal tender for the payment
of debts contracted after. its passage and that of an act making them a
legal tender for the discharge of all debts, as well those incurred be-
fore, as those made after its enactment. There may bea difference in
the effects produced by the acts, and in the hardship. of their operation,
but in both cases the fundamental question, that which tests the validity
of the legislation, is, can Congress constitutionally give to treasury notes
the character and qualities of money? Can such notes he constituted a
legitimate circulating medium, having a defined legal value? If they
can, then such notes must be available to fulfill all contracts (not ex-
pressly excepted) solvable in money, without reference to the time when
the contracts were made. Hence, it is not strange that those who hold
the legal tender acts unconstitutional when applied to contracts made
before February, 1862, find themselves compelled also to hold that the
acts are invalid as to debts created after that time, and to hold that both
classes of debts alike can be discharged only by gold and silver coin.
PROMISSORY NOTES. 393
470. The General Rule. And it may be laid down as a
general rule that where the note or contract contains no stipu-
lations for the payment of interest, still the holder may recover
legal interest from and after the maturity of the note or con- -
tract.?
2 Edwards on bills and notes, 708; 19 John 246.
The consequences of which we have spoken, serious as they are, must
be accepted, if there is a clear incompatibility between the constitution
and the legal tender acts. But we are unwilling to precipitate them
upon the country unless such an incompatibility plainly appears. A
decent respect for a co-ordinate branch of the government demands that
the judiciary should presume, until the contrary is clearly shown, that
there has been no transgression of power by Congress—all the members
of which act under the obligations of an oath of fidelity to the constitu-
tion. Such has always been the rule. In Commonwealth vs. Smith, the
language of the court was: “It must be remembered that for weighty
reasons, it has been assumed as a principle, in construing constitutions,
by the Supreme Court of the United States, by this court, and by every
other court of reputation in the United States, that an act of the legisla-
ture is not to be declared void unless the violation of the constitution is
so manifest as to leave no room for reasonable doubt ;” and in Fletcher
vs. Peck, Chief Justice Marshall said: ‘“It is not on slight implication
and vague conjecture that the legislature is to be pronounced to have
transcended its powers and its acts to be considered void. The opposi-
‘tion between the constitution and the law should be such that the Judge
feels a clear and strong conviction of their incompatibility with each
other.” Itis incumbent, therefore, upon those who affirm the unconsti-
tutionality of an act of Congress to show clearly that it is in violation of
the provisions of the constitution It is not sufficient for them that they
succeed in raising a doubt. Nor can it be questioned that, when investi-
gating the nature and extent of the powers conferred by the constitution
upon Congress, it is indispensible to keep in view the objects for which
those powers were granted. This is a universal rule for construction ap-
plied alike to statutes, wills, contracts and constitutions. If the general
purpose of the instrument is ascertained, the language of its provisions
must be construed with reference to that purpose and so as to subserve
it. In no other way can the intent of the framers of the instrument be
394 LAW OF DAMAGES.
471. Rate Fixed by Law will Govern in the Absence of Special
Agreement. Where the rate of interest is not specified in the
contract, the holder will be allowed the rate fixed by the law
where the contract is made payable. And if no place for pay-
ment is specified in the contract the presumption will be that
it is payable in the State where it was made and interest will
be computed at the rate allowed by the law of that State.’
3 Sweet v Dodge, 48. M. & M. 44; Edwards on bills and notes, 714.
discovered. And there are more urgent reasons for looking to the ulti-
mate purpose in examining the powers conferred by a constitution, than
there are in construing a statute, a will ora contract. We do not expect -
to find in a constitution minute details. It is necessarily brief and com-
prehensive. It prescribes outlines, leaving the filling up to be deduced
from the outlines. In Martin vs. Hunter, it was said: ‘‘The constitu-
tion unavoidably deals in general language. It did not suit the purpose
of the people in framing this great charter of our liberties, to provide for
minute specifications of its powers, or to declare the means by which
those powers should be carried into execution.” And with singular
clearness was it said by Chief Justice Marshall, in McCulloch v. The
State of Maryland: ‘A constitution to contain an acurate detail of all
the subdivisions of which its great powers will admit, and of all the
means by which it may be carried into execution, would partake of the
prolixity of a political code, and would scarcely be embraced by the
human mind. It would probably never be understood by the public.
Its nature, therefore, requires that only its great outlines should be
marked, its important objects designated, and the minor ingredients
“which compose those objects be deducted from the nature of the objects
themselves.” If these are correct principles, if they are proper views of
the manner in which the constitution is to be understood, the powers
conferred upon Congress must be regarded as related to each other, and
all means fora common end. Each is but part of a system, a constituent
of one whole. No single power is the ultimate end for which the consti-
tution was adopted. It may, in a very proper sense, be treated as a
means for the accomplishment of a subordinate object, but that object is
itself a means designed for an ulterior purpose Thus the power to levy
and collect taxes, to coin money and regulate its value, to raise and sup-
port armies, orto provide for and maintain a navy, are instruments of
PROMISSORY NOTES. 395
472. Note is Assigned in One State and is Sent to an Agent the
Rate of Delivery Governs. Where a note is signed and indorsed
in one State and is sent to the agent of the maker to be de-
livered to the payee in another, the rate of interest at the place
of delivery will be allowed and the contract of indorsement will
be governed by the law of the same place. The place of de-
livery is considered the place where the note was executed.!
* Cook v. Litchfield, 5 Sand. 330; Hyde v. Goodman, 3 Conn. 266.
the paramount object, which was to establish a government, sovereign
within its sphere, with capability of self preservation, thereby forming a
union more perfect than that which existed under the old confederacy.
The same may be asserted also of all the non-enumerated powers in-
cluded in the authority expressly given, ‘‘to make all laws which shall
be necessary and proper for carrying into execution the specified powers.
vested in Congress, and all other powers vested by the constitution in
the government of the United States, or in any department or officer
thereof’’ It certainly was intended to confer upon the government the
power of self-preservation. Said Chief Justice Marshall, in Cohens vs.
the Bank of Virginia: ‘America has chosen to be in many respects and
to many purposes a nation, and for all these purposes her government is
complete; for all these objects itis supreme. It can then in effecting
these objects legitimately, control all individuals or governments within
the American territory.” He added in the same case:° ‘A constitution
is framed for ages to come, and is designed to approach immortality as
near as mortality can approach it. Its course cannot always be tranquil.
It is exposed to storms and tempests, and its framers must be unwise
statesmen, indeed, if they have not provided it as far as its nature will
permit with the means of self-preservation from the perils it is sure to
encounter.” s That would appear, then, to be a most unreasonable con-
struction of the constitution which denies to the government created by
it the right to employ freely every means not prohibited necessary for its
preservation, and for the fulfillment of its acknowledged duties. Such a
right, we hold, was given by the last clause of the eighth section of its
first article. The means or instrumentalities referred to in that clause,
and authorized, are not enumerated ox defined. In the nature of things
enumeration and specification were impossible. But they were left to
the discretion of Congress, subject only to the restriction that they be
396 LAW OF DAMAGES.
473. Note Payable in One State is Passed into Another. Where
a note is made in one State and is passed into another, or when
the payor of a note executes it in one State and before it is due
or collected, removes and settles in another, and suil is brought
in the court of the State in which he resides, the rate of in-
terest in the State where the note was made will be allowed in
assessing damages, notwithstanding the fact that it may ex-
ceed the rate ‘allowed by the law of the State where the suit is
brought.®
5 Lines v. Mack, 19 Ind. 223, —
not prohibited and be necessary and proper for carrying into execution
the enumerated powers given to Congress, and all other powers vested
in the government of the United States or in any department or officer
thereof.
And here it is to be observed it is not indispensible to the existence of
any power claimed for the Federal government that it can be found
specified in the words of the constitution, or clearly and directly tracea-
ble to some one of the specified powers. Its existence may be deduced
fairly from more than one of the substantive powers expressly defined,
or from them all combined. It is allowable to group together any num-
ber of them and infer from them all that the power claimed has been
conferred. Such a treatment of the constitution is recognized by its own
provisions. This is well illustrated in its language respecting the writ
of habeas corpus. The power to suspend the privilege of that writ is not
expressly given, nor can it be deduced from any one of the particularized
grants of power, yet it is provided that the privileges of the writ shall not
be suspended except in certain defined contingencies. This is no express
grant of power. It isa restriction. But it shows irresistibly that some-
where in the constitution, power to suspend the privileges of the writ
was granted either by some one or more of the specifications of power,
or by them all combined. And that important powers were understood
by the people who adopted the constitution to have been created by it,
powers not enumerated and not included incidentally in any one of
those enumerated, is shown by the amendments. The first ten of these
were suggested in the conventions of the States and proposed at the first
session of the first Congress before any complaint was made of a disposi-
PROMISSORY NOTES.. 397
474, General Rule. From these authorities it will be per-
ceived that the damages that can be recovered in a suit on a
promissory note will depend to a very great extent on the
place of payment. Chancellor Kent, in commenting on the
subject, says: “The law of the place where the contract is
made is to determine the rate of interest where the contract
specifically gives interest, and this will be the case though the
loan be secured by mortgage on land in another State, unless
there be circumstances to show that the parties had in view
the law of the latter place, in respect to interest. When that
is the case the rate of interest at the place of payment is to
govern.’*
5 2 Kentcom., 460; see Story on conflict of law, sec. 305.
tion to assume doubtful powers. The preamble to the resolution sub-
mitting them for adoption recited that the “conventions of a number of
the States had, at the time of their adopting the constitution, expressed
a desire, in order to prevent misconstruction or abuse of its powers, that
further declaratory and restrictive clauses should be added.” This was
the origin of the amendments, and they are significant. They tend
plainly to show that, in the judgment of those who adopted the constitu-
tion, there were powers created by it neither expressly specified nor de-
ducible from any one specified power, or auxiliary to it alone, but which
grew out of the aggregate powers conferred upon the government, or out
of the sovereignty institutzd. Most of these amendments are denials of
power which have not been expressly granted, and which cannot be said
to have been necessary and proper for carrying into execution any other
-powers. Such, for example, is the prohibition of any laws respecting
the establishment of religion, prohibiting the free exercise thereof or
abridging the freedom of speech or of the press.
And it is of importance to observe that Congress has often exercised,
without question, powers that are not expressly given nor auxiliary to
any single enumerated powers. Powers thus exercised are what are
called by Judge Story, in his Commentaries on the Constitution. result-
ing powers, arising from the aggregate powers of the government. He
instances the right to sue and make contracts. Many others might be
given. The oath required by law from officers of the government is one.
398 LAW OF DAMAGES.
475. The General Principle. The general principle in rela- -
tion to contracts made in one place to be executed in another,
is well settled. They are to be governed by the law of the
place of performance, and if the interest allowed by the place
of performance is higher than that permitted at the place of
the contract, the parties may stipulate for the higher interest
without incurring the penalty of usury.’
476. Rule Where the Rate Specified in the Note is Forbidden by
- Law. But where the rate of interest specified in a note is for-
bidden by the laws of both the States where it is made and to
be executed, it cannot be recovered.”
® Andrews vy. Pond, 15 Curtis U. S, 42; 13 Peter 65.
7 Andrews v. Pond, supra.
So is building a Capitol or a Presidential mansion, and so also is the
penal code. This last is worthy of brief notice. Congress is expressly
authorized “to provide for the punishment of counterfeiting the securi- -
ties and current coin of the United States, and to define and punish pir-
acies and felonies committed on the high seas and ‘offenses against the
laws of nations.” It is also empowered to declare the punishment of
treason, and provision is made for impeachments. This isthe extent of
power to punish crime expressly conferred. It might be argued that the
expression of these limited powers implies an exclusion of all other sub-
jects of criminal legislation. Such is the argument in the present cases.
It is said because Congress is authorized to coin money and regulate its
value, it cannot declare anything other than gold and silver to be money
or make it a legal tender, yet Congress by the act of April 30, 1790, enti-
tled, “An act more effectually to provide for the punishment of certain
crimes against the United States,” and the supplementary act of March
3, 1825, defined and provided for the punishment of a large class of crimes
. other than those mentioned in the constitution, and some of the punish-
ments prescribed are manifestly not in aid of any single substantive
power. No one doubts that this was rightfully done, and the power thus
exercised has been affirmed by this court in United States v. Marigold, 9
Howard 560. This case shows that a power may exist as an aid to the
execution of an express power or an aggregate of such powers, though
PROMISSORY NOTES. 399
477. Two Kinds of Money. Under the laws of the United
States we now have two kinds of money made by the law ex-
actly equivalent for the purpose of paying ordinary debts and
of about equal value, but this has not been so for any length of
time. During the existence of our late war and until the com-
mencement of the year 1879, the legal tender notes were depre-
ciated in value. And the courts of the different States were
frequently perplexed with questions as to the constitutionality
of the legal tender acts. It was contended by quite a number
there is another express power given relating to the same subject, but
less extensive. Another illustration of this may be found in connection
with the provisions respecting a census. The constitution orders an
enumeration of free persons in the different States every ten years.' The
direction extends no further, yet Congress has repeatedly directed an
enumeration not only of free persons in the States, but of free persons in
the Territories, and not only an enumeration of persons but the collec-
tion of statistics respecting age, sex and production. Who questions the
power to do this? ,
Indeed, the whole history of the government and of Congressional leg-
islation has exhibited the use of a very wide discretion, even in times of
peace and in the absence of any trying emergency, in the selection of the
necessary and proper means to carry into effect the great objects for
which the government was framed, and this discretion has generally
been unquestioned, or, if questioned, sanctioned by this court. This is
true not only when an attempt has been made to execute a single power
specifically given, but equally true when the means adopted have been
appropriate to the execution not of a single authority, but of all the
powers created by the constitution. Under the power to establish post-
offices and post-roads, Congress has provided for carrying the mails,
_ punishing theft of letters and mail robberies, and even for transporting
the mails to foreign countries. Under the power to regulate commerce,
provision has been made by law for the improvement of harbors, the
establishment of observatories, the erection of lighthouses, breakwaters
and buoys, the registry, enrollment and construction of ships, and a code
has been enacted for the government of seamen. Under the same power
and other powers over the revenue and the currency of the country, for
the convenience of the treasury and internal commerce, a corporation
400 LAW OF DAMAGES.
of persons who were holders of great wealth and had large sums
of money at interest, that Congress possessed no power under
the constitution to make the promissory notes of the govern-
ment a legal tender for any purpose; that the constitution no-
where granted such power to Congress in expressed terms, and
that it was not properly incidented to any other power that
known as the United States Bank was early created. To its capital the
government subscribed one-fifth of its stock. But the corporation was a
private one, doing business for its own profit. Its incorporation was a
constitutional exercise of Congressional power for no other reason than
that it was deemed to be a convenient instrument or means of accom-
plishing one or more of the ends for which the government was estab-
lished, or, in the language of the first article already quoted, ‘‘necessary
and proper” for carrying into execution some or all the powers vested in
the government. Clearly this necessity. if any existed, was not a direct
and obvious one, yet this court in McCulloch vs. Maryland (4 Wheaton
416) unanimously ruled that in authorizing the bank, Congress had not
transcended its powers. So debts due to the United States have been
declared by acts of Congress entitled to priority of payment over debts
due to other creditors, and this court has held such acts warranted by
the constitution, (Fisher vs. Bright, 2 Cranch 358 )
This is enough to show how, from the earliest period of our existence
as a nation, the powers conferred by the constitution have been construed
by Congress and by this court wherever such action by Congress has
been called in question. Happily the true meaning of the clause author-
izing the enactment of all laws necessary and proper for the carrying into
execution the express powers conferred upon Congress and.all other
powers vested in the government of the United States, or in any of its
departments or officers, has long since been settled In Fisher vs.
Bright (2 Cranch 358), this court, speaking by Chief Justice Marshall,
said that in construing it it would be incorrect and would produce end-
less difficulties if the opinion should be maintained that no law was
authorized which was not indispensibly necessary to give effect to a spe-
cific power. Where various systems might be adopted for that purpose,
it might be said with respect to each that it was not necessary, because
the end might be obtained by other means. “Congress,” said this court,
“must possess the choice of means, and must be empowered to use any
PROMISSORY NOTES.. 401
was directly granted. They contended that the power author-
izing Congress to borrow and coin money and to regulate the
value thereof, did not carry with it by implication the author-
ity to make the notes of the government a legal tender in pay-
ment of debts. The almost unanimous opinions of the State
courts were that Congress possessed the power under the con-
stitution to issue the legal tender notes, commonly called
greenbacks, and make them lawful money and a legal tender
for all debts. Those contracted before, as well as those con-
tracted after the acts authorizing their issue took effect, and
that contracts made payable in gold and silver coin could be
satisfied by payment of legal tender notes.’
2'Troutman v. Gouring, 16 Iowa 415.
means which are,\in fact, conducive to the exercise of a power granted
by the constitution. The government isto pay the debt of the Union,
and must be authorized to use the means which appear to itself most
eligible to effect that object. It has, consequently, a right to make re~
mittances by bills or otherwise, and to take those precautions which will
render the transaction safe.” It was in this case, as we have already re-
marked, that a law giving priority to debts due to the United States was
ruled to be constitutional, for the reason that it appeared to Congress to
be an eligible means to enable the government to pay the debts of the
Union.
It was, however, in McCulloch vs. Maryland that the fullest considera-
tion was given to this clause of the constitution granting auxiliary
powers, and a construction adopted that ‘has ever since been accepted as
determining its true meaning. We shall not now go over the grounds
there trodden. It is familiar to the legal profession, and, indeed, to the
whole country. Suffice to say, in that case it was finally settled that in
the gift by the constitution to Congress of authority to enact laws ‘‘neces-
sary and proper” for the execution of all the powers created by it, the
necessity spoken of is not to be understood as an absolute one. On the
contrary, this court then held that the sound construction of the consti-
tution must allow to the national legislature that discretion with respect
to the means by which the powersit confers are to be carried into execu-
tion, which will enable that body to perform the high duties assigned to
402 LAW OF DAMAGES.
This doctrine was acquiesced in, notwithstanding the
great hardship that it worked on those who had prior to the
taking effect of the legal tender acts loaned their gold and sil-
ver out at alow rate of interest, with the expressed agreement
and understanding that they should have gold in return. This
was supposed to be the law until the Supreme Court of the
United States decided otherwise. They held in the case of
Brown vs. Rhodes that where the contract between the parties
stipulated that it should: be paid in gold and silver, that it
could only be liquidated in that kind of money, overruling the
it in the manner most beneficial to the people. Said Chief Justice Mar-
shall, in delivering the opinion of the court: ‘Let the end be legitimate,
let it be within the scope of the constitution and all means which are ap-
propriate, which are plainly adapted to that end, which are not prohib-
ited, but consistent with the letter and spirit of the constitution are con-
stitutional.” The case also marks out with admirable precision the
province of this court. It declares that ‘when the law (enacted by Con™
gress) is not prohibited and is really calculated to effect any of the ob-
jects instrusted to the government, to undertake here to inquire into the
degree of its necessity would be to pass the line which circumscribes the
judicial department and to tread on legislative ground. This court (it
was said) disclaims all pretentions to such a power.” Itis hardly neces-
sary to say that these principles are received with universal assent.
Even in Hepburn vs. Griswold (8 Wallace 603), both the majority and
minority of the court concurred in accepting the doctrines of McCulloch
vs. Maryland as sound expositidns of the constitution, though disagree-
ing in their application.
With these rules of constitutional construction before us, settled ata
period in the history of the government, hitherto universally accepted,
and not even now doubted, we have a safe guide to a right decision of
the questions before us. Before we can hold the legal tender acts uncon-
stitutional, we must be convinced they were not appropriate means, or
means conducive to the execution of any or all of the powers of Congress,
or of the government, not appropriate in any degree (for we are not
judges of the degree of appropriateness), or we must hold that they were
prohibited. This brings us to the inquiry whether they were, when
PROMISSORY NOTEN. — 408
decisions of the State courts. The court says, in rendering the
decision that this was a promise to pay coin dollars: “The
terms of the contract must have been selected to fix definitely
the contract between the parties and to guard against any pos-
sible claims that payment in ordinary currency ought: to be
accepted. The intent of the parties is, therefore, clear. What-
ever might be the forms or fluctuations of the note currency,
this contract was not to be affected by them. It was to be paid
at all events in coined lawful money.” j
7 Bronson v. Rhodes, 7 Wallace 229.
enacted, appropriate instrumentalities for carrying into effect or exe”
cuting any of the known powers of Congress,.or of any department of
the government. Plainly, to this inquiry a consideration of the time
when they were enacted, and of the circumstances in which the govern-
ment then stood, is important. It is not to be denied that acts may be
adapted to the exercise of lawful power, and appropriate to it, in seasons
of exigency, which would be inappropriate at other times.
We do not propose to. dictate at length upon the circumstances in
which the country was placed when Congress attempted to make
. treasury notes a legal tender. They are of too recent occurrence to jus-
tify enlarged description. Suffice it to say, that a civil war was then
raging which seriously threatened the overthrow of the government and
the destruction of the constitution itself. It demanded the equipment
and support of large armies and navies and the employment of money
to an extent beyond the capacity of all ordinary sources of supply.
Meanwhile the public treasury was nearly empty, and the credit of the
government, if not stretched to its utmost tension, had become nearly ex-
hausted. Monied institutions had advanced largely of their means, and
more could not be expected of them. They had been compelled to sus-
pend specie payments. Taxation was inadequate to pay even the in-
terest on the debt already incurred, and it was impossible to await the
income of additional taxes. The necessity was immediate and pressing.
The army was unpaid, There was then due to the soldiers in the field
“nearly a score of millions of dollars. The requisitions from the war and
navy departments for supplies exceeded fifty millions and the current
expenditure was over one million per day. The entire amount of coin
404 LAW OF DAMAGES.
478. They held in this case also that a contract to pay a
certain number of dollars in gold or silver coin is, therefore, in
egal import nothing else than an agreement to deliver a cer-
tain weight of standard gold or silver to be ascertained by a
count of coin, each of which is certified to containing a definite
proportion of the weight. It is not distinguished, the court
says, in principle from a contract to deliver an equal weight of
bullion of equal fineness. The only difference being in the
method of ascertaining the amount of the precious metals. In
in the country, including that in private hands, as well as that in bank-
ing institutions, was insufficient to supply the need of the government
for three months, had it all been poured into the treasury. Foreign
credit we had none. We say nothing of the overhanging paralysis of
trade, and of business generally which threatened loss of confidence in
the ability of the government to maintain its continued existence, and
therewith the complete destruction of all remaining national credit.
It was at such a time and in such circumstances that Congress was
called upon to devise means for maintaining the army and navy, for se-
curing the large supplies of money needed, and, indeed, for the preserva-
tion of the government, created by the constitution. It was at such a
time and in such an emergency that the legal tender acts were passed.
Now, if it were certain that nothing else would have supplied the abso-
lute necessity of the treasury, that nothing else would have enabled the
government to maintain its armies and navy, that nothing else would
have saved the government and constitution from destruction, while the
legal tender act would, could any one behold enough to assert that Con-
gress transgressed its powers? Or, if these enactments did work these
results, can it be maintained now that they were not for a legitimate
end, or “appropriate and adopted to that end,” in the language of Chief
Justice Marshall? That they did work such results is not to be doubted.
Something revived the drooping faith of the people; something brought
immediately to the government’s aid the resources of the nation, and
something enabled the successful prosecution of the war and the preser-
vation of the national life. What was it if not the legal tender enact-
ments?
But if it be conceded that some other means might have been chosen
PROMISSORY NOTES. 405
|
case of bullion, the amount would be ascertained by assay and
the scales, but in case of coin the amount is easily ascertained
by count, as the government has weighed it and marked it one
dollar, which is known to contain so many grains of the pre-
cious metals.
’ Bronson v. Rhodes, supra.; Dering v. Leas, 11 Wall (U. 8.) 379; Kel-
logg v. Sweeny, 46 N. Y. 291; Crysler v. Renos, 43 N. Y. 209; Phelps v.
Speyers, 49 N. Y. 653; Ind. Insurance Co. y. Thomas, 104 Mass. 192; Car-
penter v. Atherton, 25 Cal. 564; Lane v. Gulckaut, 28 Cal. 288; Harding
v. Couing, 28 Cal. 212; Reeves v. Stearns, 2 Cal. 273; Tarpy v. Shepherd,
30 Cal. 180; Pratt y. Stearns, 31 Cal. 78; Clark v. Nevada L. & M. Co., 6
Nev. 203.
for the accomplishment of these legitimate and necessary ends, the con-
cession does not weaken the argument. It is urged now, after the lapse
of nine years, and when the emergency has passed, that treasury notes
without the legal tender clause might have been issued, and that the
necessities of the government might thus have been supplied. Hence,
it is inferred there was no necessity for giving to the notes issued the
capacity of paying private debts. At best this is mere conjecture. But
admitting it to be true, what does it prove? Nothing more than that
Congress had the choice of means for a legitimate end, each appropriate
and adapted to that end, though, perhaps, in different degrees. What
then? Can this court say that it ought to have adopted one rather than
the other? Is it our province to decide that the means selected were be-
yond the constitutional power of Congress, because we may think that
other means to the same end would have been more appropriate and
equally efficient? That would be to assume legislative power, and to
‘disregard the accepted rules for construing the constitution. The de-
gree of the necessity for any Congressional enactment, or the relative
degree of its appropriateness, if it have any appropriateness, is for con-
sideration in Congress, not here. Said Chief Justice Marshall, in McCul-
loch vs. Maryland, as already stated: ‘When the law is not prohibited,
and is really calculated to effect any of the objects intrusted to the gov-
ernment, to undertake here to inquire into the degree of the necessity,
would be to pass the line which circumscribes the judicial department,
and to tread on legislative ground.”
406 LAW OF DAMAGES.
479. From this decision the rule may be laid down that
when it appears to be the clear intent of a contract that pay-
ment or satisfaction of it shall be made in gold or silver, dam-
ages should be assessed and judgment entered accordingly.
The question whether the greenback notes, made a legal ten-
der for all debts, public and private, except duties on imports,
etc., were a legal tender for debts on contracts made before the
legal tender act’ were passed, was for many years unsettled,
but after much difficulty and dissension the Supreme Court of
the United States, after a very full consideration of all the
authorities, held that debts so contracted could be discharged
and paid in legal tender notes or greenbacks.’
480. Indiana Rule. Where the defendant received gold
and silver coin as bailee of the plaintiff, and on request failed
2 Dooley v. Smith, 13 Wallace 604; Legal tender cases, 12 Wallace, 457.
It is plain to our view, however, that none of those measures which it
is now conjectured might have been substituted for the legal tender acts,
could have met the exigencies of the case at the time when those acts
were passed. We have said that the credit of the government had been
tried to its utmost endurance. Every new issue of notes which had
nothing more to rest upon than government credit, must have paralyzed
it more and more, and rendered it increasingly difficult to keep the army
in the field or the navy afloat. It is an historical fact that many persons
and institutions refused to receive and pay those notes that had been
issued, and even the head of the treasury represented to Congress the
necessity of making the new issues legal tenders, or rather declared it
impossible to avoid the necessity. The vast body of men in the military
service was composed of citizens who had left their farms, their work-
shop, and their business, with families and debts to be provided for.
The government could not pay them with ordinary treasury notes, nor
could they discharge their debts with such a currency. Something more
was needed, something that had all the uses of money. And as no one
could be compelled to take common treasury notes in payment of debts
and as the prospect of ultimate redemption was remote and contingent,
PROMISSORY NOTES. 407
and refused to deliver it up, it was held that such a refusal
was a gonversion of the money, and that the plaintiff could re-
cover its full value.’
481. The Rules Deducible from all the Decisions. From all the
decisions that we have been able to examine, the following
rules may be deduced:
1. In an action on a note, the measure of damages is the prin-
cipal, with legal interest.
3 ‘The Bank of the State v. Burton, 27 Ind. 426.
“Tn an action for conversion or negligent loss of United States coin, it
is acontroverted question whether the judgment should be for the value
of the coin in legal tender notes or for the amount of the coin itself in
specie. On this question, it seems, the courts of New York and Massa-
chusetts differ, the former holding in favor of a judgment for coin itself,
and the latter its value computed in treasury notes.” Cushing v. Wells,
Fargo & Co., 9 Mass. 550; Kellogg v. Sweeney, 46 N. Y. 291; Field on
damages, 205.
it is not too much to say that they must have depreciated in the market
long before the war closed, as did the currency of the Confederate States.
Making the notes legal tenders gave them a new use, and it needs no
argument to show that the value of things is in proportion to the uses to
which they may be applied.
It may be conceded that Congress is not authorized to enact laws in
furtherance even ofa legitimate end merely because they are useful, or
because they make the government stronger There must be some rela-
tion between the means and end, some adaptedness or appropriateness
of the laws to carry into execution the powers created by the constitu-
tion. But when a statute has proved effective in the execution of pow-
ers confessedly existing, it is not too much to say that it must have had
some appropriateness to the execution of those powers. The rules of
construction heretofore adopted do not demand that the relationship be-
tween the means and the end shall be direct and immediate. TIllustra-
tions of this may be fourd in several of the cases above cited. The char.
408 LAW OF DAMAGES. =
2. That where there is a promise to pay money in the Uni-
ted States and it is not specified in the contract that it is to be
paid in gold, silver or legal tender notes, it will be satisfied by
a tender of the amount in either.
3. That if gold or silver is applied to the payment of a claim
not payable in coin, it will be received at its nominal value,
and no per cent. on it can be allowed.
4, That where a contract is made payable in gold or silver
coin, it must be paid in specie, and cannot be satisfied or paid
in legal tender notes, and judgment should be rendered for the
money specified in the contract, with interest.
482, Interest Continued to Run During-the Civil War. In the
case of Spence vs. Brown, which was a suit brought upon two
promissory notes for the sum of one thousand dollars each, pay-
able in the State of New York, the defendant tried to defeat
the recovery of the accrued interest, because of the prevalence
of a state of war between the citizens of the State of Texas and
ter of a bank of the United States, the priority given to debts due the
government over private debts, and the exemption of Federal loans from
liability to State taxation, are only a few of the many which might be
given. The case of Veazie Bank vs. Fenno (8 Wallace 533) presents a
suggestive illustration. There a tax of ten per cent. on State Bank notes
in circulation was held constitutional, not merely because it was a means
of raising revenue, but as an instrument to put out of existence such a
circulation in competition of notes issued by the government. There,
this court speaking through the Chief Justice, avowed that it is the con-
stitutional right of Congress to provide a currency for the whole coun-
try; that this might be done by coin or United States notes, or notes of
National banks; and that it cannot be questioned that Congress may
constitutionally secure the benefit of such a currency to the people by
appropriate legislation. It was said there can be no question of the
PROMISSORY NOTES. 409
the citizens of the United States, which put it out of the power
of the obligor to make payment. The plaintiff filed a demurrer
to the answer, which was sustained by the court. It was held
that in time of war, in which parties to a contract are in hos-
tility to each other, the judicial enforcement of the contract is
in abeyance, but that their obligation does not cease, and that
with the restoration of peace the remedy revived, and the
plaintiff could maintain his action and recover all interest
from the maturity of the note until the trial.
483. Wheaton vs. Pike In this case suit was brought on
a promissory note made payable at a given time after date,
with interest, payable semi-annually. Held, that interest
might be computed in making up the judgment on all the in-
stallments of interest overdue and remaining unpaid, but that
‘
1 32 Texas 663; Bigler v. Wall, 3 Am. L. T. R. 157; Ward v. Smith,
Wall 447. ;
power of the government to emit bills of credit; tomake them receivable
in payment of debts to itself; to fit them for use for those who see fit to
use them in all the transactions of ‘commerce; to make ‘them a currency
uniform in value and description, and conxenient and useful for circula-
tion. Here the substantial power to tax was allowed to be employed for
improving the currency. It is not easy to see why, if State Bank notes
can be taxed out of existence for the purpose of indirectly making Uni-
ted States notes more convenient and useful for commercial purposes,
the same end may not be secured directly by making'them a legal tender.
Concluding then that the provisions which made treasury’ notes a
legal tender for the payment of all debts other than those expressly ex-
cepted was not an inappropriate means for carrying into execution the
legitimate powers of the government, we proceed to inquire whether it
was forbidden by the letter or spirit of the constitution. It is not
claimed that any express prohibition exists, but it is insisted that the
spirit of the constitution was violated by the enactment Here those
who assert the unconstitutionality of the acts mainly rest their argu-
ment. They claim that the clause which conferred upon Congress
410 LAW OF DAMAGES.
no installment of semi-annual interest should be considered
as due after the maturity of the note, because after that both
the accruing interest and the principal were due, not on any
particular day, but every day till they were paid.’
484. Perry vs. Gleason. In the case of Perry vs. Gleason,
the Court of Appeals of the State of New York held where the
plaintiff brought an action on a note which was a promise to
pay a certain amount of money in salt at fourteen shillings per
barrel, that it was an agreement to deliver to the holder a cer-
tain quantity of salt at a stipulated price per barrel, and that
the plaintiff could only recover the value of the salt on the day
specified for the payment.’
2 Wheaton v. Pike, 9 R. I. 182; Pierce v. Rowe, 1 N. H. 179; Catlin v,
Lyman; 16 Vt. 44; Mann v. Cross, 9 Iowa 327; Daig v. Barkly, 3 Lewis 2,
75 Wend. 339. :
The Supreme Court of Tennessee held to the same opinion in the case
of McDonald v. Hodge, 5 Haywood’s Tenn. R. 85. But differently in the
State of Georgia. Simms v. Cox, 4 Georgia 76.
power “‘to coin money, regulate the value thereof, and of foreign coin,”
contains an implication that nothing but that which is subject of coin-
age, nothing but the precious. metals, can ever be declared by law to be
money, or to have the use of money. If by this is meant that because
certain powers over the currency are expressly given to Congress, all
other powers relating to the same subject are impliedly forbidden, we
need only remark that such is not the manner in which the constitution
has always been construed. On the contrary, it has been ruled that
power over a particular subject may be exercised as auxiliary to an ex-
press power, though there is another express power relating to the same
subject less comprehensive. There an express power to punish a cer-
tain class of crimes (the only direct reference to criminal legislation con-
tained in the constitution) was not regarded as an objection to deducing
authority to punish other crimes from another substantive and defined
grant of power. There are other decisions to the same effect. To assert
then that the clause enabling Congress to coin money and regulate its
PROMISSORY NOTES. 4l1
485, Interest Can be Recovered After the Payment of the Princi-
pal. It isnow pretty generally held that where there is no
agreement to pay interest, that it can be only recovered as
damages for the non-payment of the principal debt when it
becomes due. In such case, if the party to whom the money is
payable accepts the amount agreed to be paid in full satisfac-
tion without requiring the debtor to pay interest from the
time the debt became due, he cannot afterward maintain a suit
to recover the interest.’ But where there is an expressed
promise or agreement to pay interest, as well as principal, of
the plaintiffs demand, and the principal has been paid or a
new note or bill given for it and interest which was due was
not paid, it remains due and an actjon may be maintained for
it.®
2 Lake v. Eddy, 15 Wend. 76; Robbins v. Cheek, 32 Ind. 328; White-
water C. Co. v. Hawkins, 4 Ind. 474; Watkins v. Morgan, 6 C. & P. 661.
* 2 Parsons on notes and bills, 375.
value tacitly implies a denial -of all other power over the currency of the
nation, is an attempt to introduce a new rule of construction against the
solemn decisions of this court. (U.S. v. Marigold, 9 Howard 560.) So
far from its containing a lurking prohibition, many have thought it was
intended to confer upon Congress that general power over the currency
which has always been an acknowledged attribute of sovereignty in
every other civilized nation than our own, especially when considered
in connection with the other clause which denies to the States the power
to coin money, emit bills of credit, or make anything but gold and silver
coin a tender in payment of debts. We do not assert this now, but there
are some considerations touching these clauses which tend to show that
if any implications are to be deduced from them they are of an enlarg-
ing rather than a restraining character. The constitution was intended
to frame a government as distinguished from a league or compact, a gov-
ernment supreme in some particulars over State and people. It was de-
signed to provide the same currency having a uniform legal value in all
the States. It was for this reason the power to coin money and regulate
its value was conferred upon the Federal Government, while the same
412 LAW OF DAMAGES.
486. Conflict of Authorities. We have seen in the discus-
sion of this question of interest that the authorities are at
variance in reference to the rate of interest that a promissory
note raade in one State and payable in another should bear.
This being true, we are left to recominend either rule.
According to some of these authorities, if a note is made paya-
ble at a certain designated place it must in respect to interest
conform to the law of the placé of payment without reference
to the place where it was signed.*
According to others, if a note is made in one State and
payable in another, and the interest law in such States are in
conflict, the law of either State may be applied; in other words,
that such a note may have two different States or places, the
laws of which may enter into its construction, and that should
be considered by the court in determining its validity.*
+2 Kent com., 458-461; Depaw v. Humphries, 10 Martin 1; 2 Parson on
contract, 583-585; Andrews v. Pond, 13 Peter 77; DeWolf v. Johnson, 10
Wheat 367; Duscomb v. Barker, 2 Met. 8; Mix v. Insurance Co., 11 Ind.
117; Kilgore v. Dempsy, 25 Ohio st. 413.
§ Kilgore v. Dempsy, 25 Ohio st. 413; 2 Kent com , 460-461; Depaw v.
Humphries, 10 Martin 1; 2 Parson on con., p. 583-585; Andrews v. Pond,
13 Peter 65; Peck v. Mayo, 14 Vt. 33; Chapman v. Robinson, 6 Paige 627;
Edwards on bills, 717.
A bill drawn in Illinois and delivered to the drawee in New York, is
governed by the Jaw of the latter place, but if, in good faith, it is made
payable in the former State, any rate of interest not excceding the rate
allowed in such may be recovered. Frees v. Brownell, 35 N. Y. 285.
power, as well as the power to emit bills of credit, was withdrawn from
the States. The States can no longer declare what shall be money, or
regulate its value. Whatever power there is over the currency is vested
in Congres. If the power to declare what is money is not in Congress,
it is annihilated. This may, indeed, have been intended. Some powers
that usually belong to sovereignties were extinguished, but their extin-
guishment was not left to inference. In most cases, if not all, where it
PROMISSORY NOTES. 413
* \
487. The Rule that Should be Adopted. From the authorities
and on principle, we are very much inclined to the opinion
that the latter rule, which allows the parties the privilege of
either contracting with reference to the rate of interest in the
State where the note was signed and executed or the State
where it is made payable, as they might in. guod faith agree,
should be adhered to and adopted by the courts of the different
States.’
* Depaw v. Humphries, 10 Martin 1; Peck v. Mayo, 14 Vt. 33; Chap-
man v. Robinson, 6 Paige 627; 2 Kent, 460-461; Edwards on bills, 717; 2
Parson on bills and notes, 336; Andrews v. Pond, 18 Peter 65; Kilgore v.’
Dempsy, 25 Ohio st. 413.
In the case of Depaw v. Humphries, supra., the note was given in New
Orleans, payable in New York, for a large sum of money bearing interest
at 10 per cent., being legal interest in Louisiana; the New York legal in-
terest bearing 7 per cent. only. The question was whether the note was
usurous and, therefore, void, as it would be if made in New York. The
Supreme Court of Louisiana decided that it was not usurous.
was intended that governmental powers, commonly acknowledged as
such, should cease to exist, both in the States and the Federal Govern-
ment, it was expressly denied to both, as well to the United States as to
the individual States. And generally when one of such powers was ex-
pressly denied to the States only, it was for the purpose of rendering the
Federal powers more complete and exclusive. Why, then, it may be
asked, if the design was to prohibit to the new government, as well as to
the States, that general power over the currency which the States had
when the constitution was framed, was such denial not expressly ex-
tended to the new government, as it was to the States? In view of this
it might be argued with much force that when it is considered in what
brief and comprehensive terms the constitution speaks, how sensible its
framers must have been that emergencies might arise when the precious
metals (then more scarce than now) might prove inadequate to the
necessities of the government and the demands of the people, when it is
remembered that paper money, almost exclusively in use in the States
as the medium of exchange, and when the great evil sought to be reme-
died was the want of uniformity in the current value of money, it might
414 LAW OF DAMAGES.
488, Where the defendant, a resident in the State of
Iowa, executed his promissory note in that State and date
there payable in New York, for a loan of money in Massachu-
setts, and payable to one B, who indorsed it to the plaintiff in
the State of Iowa, and to secure the note the defendant and his
wife executed a deed of trust of real estate situated in Iowa to
a trustee residing in that State and the note was delivered by
the defendant to the plaintiff indorsed in Massachusetts and
the money loaned thereon received | there pursuant to the agree-
ment entered into when the loan was negotiated, the court
held in an action to foreclose the trust deed that if the plain-
tiff and defendant in good faith and without intent to evade
the usury laws of Massachusetts contracted for the rate of in-
terest allowable in Iowa, which was greater than the legal rate
in either Massachusetts or New York, the stipulated interest
was reasonable‘and the contract could be enforced.’
2 Arnold v. Potter, 22 Ia. 195; Butts v. Odds,-11 Ia. 1,
be argued, we say, that the gift of power to coin money and regulate the
value thereof was understood as conveying general powers over the cur-
rency, the power which had belonged to the States, and which they sur-
rendered. Such a construction, it might be said, would be in close
analogy to the mode of construing other substantive powers granted to
Congress. They have never been construed literally, and the govern-
ment could not exist if they were. Thus the power to carry on war is
conferred by the power to ‘‘declare war.’’ The whole system of the
transportation of the mails is built upon the power to establish postoffices
and post roads. The power to regulate commerce has also been ex-
tended far beyond the letter of the grant Even the advocates of a strict,
literal construction of the phrase, “‘to coin money and regulate the value
thereof,” while insisting that it defines the material to be coined as
metal, are compelled to concede to Congress large discretion in all other
particulars. The constitution does not ordain what metals may be
coined, or prescribe that the legal value of the metals, when coined,
shall correspond at all with their instrinsic value in the market. Nor
does it even affirm that Congress may declare anything a legal tender for
y
PROMISSORY NOTES. 415
489. Coupon Bonds. In the case of Whitaker vs. Hart-
ford, Providence and Fishkill Railroad Company, the court
held where the suit was brought for the amount of the interest
(coupons only, the bonds not being due), that neither by their
terms nor custom are payable with interest, but are to be pre-
sented for and given upon payment. Until presented the de-
fendant could have been in no default for non-payment, but
after it (the coupons being due) the refusal to pay was a clear
breach of the contract, and interest from time of the demand
and refusal is recoverable by way of damages. Railroad bonds,
with interest coupons attached, are purchased for investment
and income, and where the latter is not paid at the time
promised no well considered authority, properly understood,
forbids what principle requires, that the damages from the de-
lay of payment should be compensated by interest on the
amount due, computed from the day of the demand and refusal.
18 R. L 47; Pierce v. Hall, 1 N. H. 179; 2 Hill 408.
the payment of debts. Confessedly the power to regulate the value of
money coined, and of foreign coins, is not exhausted by the first regula-
tion More than once in our history has the regulation been changed
without any denial of the power of Congress to change it, and it seems
to have been left to Congress to determine alike what metal shall be
coined, its purity, and how far its statutory value, as money, shall cor-
respond, from time to time, ‘with the market value of the same metal as
bullion. How then canthe grant of a power to coin money and regulate
its value, made in terms so liberal and unrestrained, coupled also with a
denial to the States of all power over the currency, be regarded as an
implied prohibition to Congress against declaring treasury notes a legal
tender, if such declaration is appropriate and adapted to carrying into
execution the admitted powers of the government?
We do not, however, rest our assertion of the power of Congress to
enact legal tender laws upon the grant. We assert only that the grant
can in no just sense be regarded as containing an implied prohibition
against their enactment, and ‘that, if it raises any implications, they are
of complete power over the currency rather than restraining.
416 LAW OF DAMAGES.
490. Conflict of Authorities. The authorities are very much
in conftict upon the question as to whether the payee of a
promissory note, which provides for the payment of interest
annually or at a specified time, can recover interest on the
accumulated interest after it becomes due, or, in other words
will the payee be allowed compound interest. In the State of
Ohio the plaintiff can recover interest on all such sums after
the default and failure to pay.” But in New Jersey and New
York, as between parties holding the relation of debtor and.
creditor, simple interest will not be compounded or .allowed
upon overdue interest.’
491. Notes Payable in Specific Articles. Where promissory
notes are made payable in specific articles and there is a breach
of the contract and a failure to pay the same at muturity, the
authorities are not uniform and harmonious on what the
measure of damages should be in case suit is brought. In New
* Cramer v. Lepper et al., 26 Ohio st. 59.
* Force v. Elizabeth City, 28 N. J. Eq. 403; Young v. Hill, 67N. Y. 162
We come next to the argument much used, and, indeed, the main re-
liance of those who assert the unconstitutionality of the legal tender acts.
It is that they are prohibited by the spirit of the constitution because
they indirectly impair the obligations of contracts. The argument, of
course, relates only to those contracts which were made before Feb-
ruary, 1862, when the first act was passed, and it has no bearing upon
the question whether the acts are valid when applied to contracts made
after their passage. The argument assumes two things, first, that the
acts do, in effect, impair the obligations of contracts, and, second, that
Congress is prohibited from taking any action which may indirectly
have that effect. Neither of these assumptions can be accepted. It is
true that under the acts a debtor, who became such before they were
passed, may discharge his debts with the notes authorized by them, and
the creditor is compellablé to receive such notes in discharge of his
claim, But whether the obligation of the contract is thereby weakened
can be determined only after considering what was the contract obliga-
PROMISSORY NO'TES.. 417
York and several other States they hold that it is a promise to
pay the note in the specified article or in money, and where
tion. It was nota duty to pay gold or silver, or the kind of money
recognized by law at the time when tle contract was made, nor was it a
duty to pay money of equal intrinsic value in the market. (We speak
now of contracts to pay money generally, not contracts to pay some
specifically defined species of money). The expectation of the creditor
and the anticipation of the debtor may have been that the contract would
be discharged by the payment of coined metals, but neither the expecta-
tion of the one party to the contract respecting its fruits, nor the antici-
pation of the other constitutes its obligation. There is a well recognized
distinction between the expectation of the parties to a contract and the
duty imposed by it. Were it not so the expectation of results would be
‘ always equivalent to a binding engagement that they should follow.
But the obligation of a contract to pay money is to pay that which the
law should recognize as money when the payment is to.be made. If
there is anything settled by decision it is this, and we do not understand
it to be controverted. No one ever doubted that a debt of one thousand
dollars, contracted before 1834, could be paid by one hundred eagles coined
after that year, though they contained no more gold than ninety-four
eagles such as were coined when the contract was made, and this, not
because of the intrinsic value of the coin, but because of its legal value.
‘The eagles coined after 1834 were not money until they were authorized
by law, and had they been coined before without a law fixing their legal
value, they could no more have paid a debt than uncoined bullion, or
cotton, or wheat. Every contract for the payment of money, simply, is
necessarily subject to the constitutional power of the government over
the currency, whatever that power may be, and the obligation of the
parties is, therefore, assumed with reference to that power. Nor is this
singular. A covenant for quiet enjoyment is not broken, nor is its obli-
gation impaired by the government taking the land granted by virtue of
its right of eminent domain. The expectation of the covenantee may be
disappointed. He may not enjoy all he anticipated, but the grant was
made and the covenant undertaken in subordination to the paramount
right of the government. We have been asked whether Congress can
declare that a contract to deliver a quantity of grain may be satisfied by
the tender of a less quantity. Undoubtedly not. But this is a false
analogy. There is a wide distinction between the tender of quantities,
418 LAW OF DAMAGES.
suit is brought the plaintiff can recover the amount of the
note, with legal interest.*
‘Perry v. Gleason, 5 Wend. 393; Chitty on contract, 35; White v.
Thompkins, 52 Pa. st. 463; Moore v. Riff, Supreme Court of Penn., not
reported; Trobridge v. Holcomb, + Ohio st. 38; Brooks v. Hubbard, 3
Conn. 58; Weil v. Tyler, 38 Mo. 545; Perry v. Smith, 22 Vt. 301; Haywood
v. Haywood, 42 Me, 229; Baker v. Mair, 12 Mass. 121; Van Hoover v. Lo-
gan, 3 Scam., Ill. 389; Smith v. Dunlap, 12 Ill. 184.
or of specific articles, and a tender of legal values. Contracts for the de-
livery of specific articles belong exclusively to the domain of State legis-
lation, while contracts for the payment of money are subject to the
authority of Congress, at least so far as relates to the means of payment.
They are engagements to pay with lawful money of the United States,
and Congress is empowered to regulate that money. It cannot, there
fore, be maintained that the legal tender acts impaired the obligation of
contracts.
Nor can it be truly asserted that Congress may not, by its actions, in-
directly impair the obligation of contracts, if by the expression he must
render the contracts fruitless, or partially fruitless. Directly it mav, con-
fessedly, by passing a bankrupt act, embracing past as well as future
transactions. This is obliterating contracts entirely. So it may relieve
parties from their apparent obligations indirectly in a multitude of ways,
It may declare war, or, even in peace, pass non-intercourse acts, or direct
an embargo. All such measures may and must operate seriously upon
existing contracts, and may not merely hinder, but relieve the parties to
such contracts entirely from performance. It is, then, clear that the
powers of Congress may be exerted, though the effect of such exertion
inay be in one case to annul, and in other cases to impair the obligation
of contracts. And it is no sufficient answer to this to say it is true only
when the powers exerted were expressly granted. There is no ground
for any such distinction. It has no warrant in the constitution, or in
any of the decisions of this court. We are accustomed to speak for mere
convenience of the express and implied powers conferred upon Con-
gress. But in fact the auxiliary powers, those necessary and appropriate
to the execution of other powers singly described, are as expressly given
as is the power to declare war, or to establish uniform laws on the sub-
ject of bankruptcy. They are not catalogued, no list of them is mades
PROMISSORY NOTES. 419
492. But in Indiana, Wisconsin and other States they
hold that in a suit on a note made payable in a designated
¢
but they are grouped in the last clause of section eight of the first article,
and granted to Congress. And this court has recognized no such dis-
tinction as is now attempted. An embargo suspends many contracts
and. renders performance of others impossible, yet the power to enforce
it has been declared constitutional. (Gibbons v. Ogden, 9 Wheaton 1.)
The power to enact a law directing an embargo is one of the auxiliary
powers, existing only because appropriate in time of peace to regulate .
commerce or appropriate to carry on war. Though not conferred as a
substantive power, it has not been thought to be in conflict with the
constitution, because it impairs indirectly the obligation of contracts.
That discovery calls for a new reading of the.constitution. If, then, the
legal tender acts were justly chargeable with impairing contract obliga-
tions, they would not for that reason be forbidden, unless a different
rule is to be applied to them from that which has hitherto prevailed in
the construction of other powers granted by the fundamental law. But
as already intimated, the objection misapprehends the nature and ex-
tent of the contract obligation spoken of in the constitution. Asina
state of civil society, property of a citizen or subject is ownership subject
to the lawful demands of the sovereign, so contracts must be understood
as made in reference to the possible exercise of the rightful authority of
the government, and no obligation of a contract can extend to the defeat
of legitimate government authority.
Closely allied to the objection we have just been considering is the,
argument pressed upon us that the legal tender acts were. prohibited by
the spirit of the fifth amendment, which forbids taking private property.
for public use without just compensation or due process of law. That
provision has always been understood as referring only to a direct ap-
propriation and not to consequential injuries resulting from the exercise
of lawful power. It has never been supposed to have any bearing upon
or to inhibit laws that indirectly work harm and loss to individuals. A
new tariff, an embargo, a draft, or a war may inevitably bring upon in-
dividuals great losses; may, indeed, render valuable property almost"
valueless. They may destroy the worth of contracts. But whoever sup
posed that, because of this, a tariff could not be changed, or a non-inter-
course act, or an embargo be enacted, or a war be declared? By the act
420 LAW OF DAMAGES.
article, that the measure of damages is ‘the value of the article
on the day the note matured.’
3 Coldren v. Miller, 1 Blackford 296; Parks v. Marshall, 10 Ind. 20;
Pierce v. Spade, 13 Ind. 458; Hobert v. Kimberly, 1 Root (Conn.) 491;
Day v. Leavenworth, ed. 519; Castice v. Whips, ed. 445; Williams v.
Jones, 12 Ind .561; Hudson v. Noble,4 J. J. Marsh. 130; Mason v. Biddle,
6 J.J. M. (Ky.) 30; Hixon v. Hixon..7 Humph. (Tenn.) 33; Kirtland v.
Moulton, 41 Ala. 548; Albert v. Citizens’ Bank, 5 La. Am. 720; Farwell v.
Kennett, 7 Miss. 595.
ty,
of June 28, 1834, a new regulation of the weight and value of gold coin
was adopted, and about six per cent. was taken from the weight of each
dollar. The effect of this was that all creditors were subjected to a cor-
responding loss. The debts then due became solvable with six per cent.
less gold than was required to pay them before. The result was thus
precisely what it is contended the legal tender acts worked. But was it
ever imagined that this was taking private property without compensa-
tion or without due process of law? Was the idea ever advanced that
the new regulation of gold coin was against the spirit of the fifth amend-
ment? And has any one in good faith avowed his belief that even alaw
debasing the current coin by increasing the alloy would be taking private
property? It might be impolitic and unjust, but could its constitutional-
ity be doubted? Other statutes have from time to time reduced the
quantity of silver in silver coin without any question of their constitu-
tionality. It is said, however, now, that the act of 1834 only brought
the legal value of gold coin more nearly into. correspondenge with its
actual value in the market, or its relative value to silver. But we do not
perceive that this varies the case or diminishes its force as an illustra-
tion. The creditor who hada thousand dollars due him on the 31st day
of July, 1834, (the day before the act took effect) was entitled to a thou-
sand dollars of coined gold of the weight and fineness of the then exist-
ing coinage. The day after he was entitled only to a sum six per cent.
less in weight and in market value, or to a smaller number of silver dol-
lars. Yet he would have been a bold man who had asserted that be-
cause of this the obligation of the contract was impaired, or that private
property was taken without compensation or without due process of
law. No such assertion so far as we know was ever made. Admit it
was a hardship, but it is not every hardship that is unjust, much less
¢ PROMISSORY NOTES. 421
493. In treating upon the measure of damages for a
breach of contract for non-payment of money, we have only re-
ferred to a few general rules established by the decision of the
courts of the different States. And this is all that we believe
that is unconstitutional, and certainly it would be an anomaly for us to
hold an act of Congress invalid merely because we might think its pro-
visions harsh and unjust.
We are not aware of anything else that has been advanced 1n support
of the proposition that the legal tender acts were forbidden by either the
letter or the spirit of the constitution. If, therefore, they were what we,
have endeavored to show, appropriate means for legitimate ends, they
were not transgressive of the authority vested in Congness.
Here we might stop, but we will notice briefly the argument presented
in support of the position that the unit of money value must possess in-
trinsic value. The argument is derived from assimilating the constitu-
tional provisions respecting a standard of weights and measures to that
conferring the power to coin money and regulate its value. It is said
there can be no uniform standard of weights without weight, or of
measure without length or space, and we are asked how anything can
be made a uniform standard of value which ‘has itself no. value? This is
a question foreign to the subject before us. The legal tender acts do not
attempt to make paper a standard of value. We do not rest their
validity upon the assertion that their emission is coinage, or any regula-
tion of the value of money; nor do we assert that Congress may make
anything which has no value money. What we do assert is, that Con-
gress has power to enact that the government’s promise to pay money
shall be, for the time being, equivalent in value to the representative of
value determined by the coinage acts, or to multiples thereof It is
hardly correct to speak of a standard of value. The constitution does
not speak of it. It contemplates a standard for that which has gravity
or extension; but value is an ideal thing. The coinage acts fix its unit as
a dollar; but the gold or silver thing we call a dollar is, in no sense, a
standard of a dollar. It is a representative of it. There might never
have been a piece of money of the denomination of a dollar. There
never was a pound sterling coined until 1815, if we accept a few ‘coins
struck in the reign of Henry VIII, almost immediately debased, yet it
has been the unit of British currency for many generations. It is, then,
422 LAW OF DAMAGES.
the profession ought to expect, asthe rate of interest is regu-
lated by the municipal laws of the different States. But for
the sake of convenience we will give in our notes the rate
of interest established by a part, if not all, of the States:
Arkansas: Six per cent. Parties may contract for an amount not ex-
ceeding ten. Dig. Ark. st., 1858, p. 622.
Alabama: Eight per cent. Contract void as to the interest at a higher
rate. Rev. code, 1867, p. 406.
a mistake to regard the legal tender acts as either fixing a standard of
value or regulating money values, or making that money which has no
intrinsic value.
But, without extending our remarks further, it will be seen that we
hold the acts of Congress constitutional as applied to contracts made
either before or after their passage. In so holding, we overrule so much
of what was decided in Hepburn vs. Griswold (8 Wallace 603) as ruled
the acts unwarranted by the constitution, so far as they apply to con-
tracts made before their enactment. That case was decided by a divided
court, and by a court having a less number of Judges than the law then
in existénce provided this court shall have. These cases have been
heard before a full court, and they have received our most careful con-
sideration. The questions involved are constitutional questions of the
most vital importance to the government, and to the public at large.
We have been in the habit of treating cases involving a consideration of
‘constitutional power differently from those which concern merely private
rights. We are not accustomed to hear them in the absence of a full
court, if it can be avoided. Even in cases involving only private rights,
if convinced we had made a mistake, we would hear another argument
and correct our error. And it is no unprecedented thing in courts of
last resort, both in this country and in England, to overrule decisions
previously made. We agree this should not be done inconsiderately,
but in a case of such far-reaching consequences as the present, thorough-
ly convinced as we are that Congress has not transgressed its powers, we
regard it as our duty so to decide and to affirm both these judgments.
The other questions raised in the case of Knox ys. Lee were substan--
tially decided in Texas vs. White, (7 Wallace 700).
Judgment in each case affirmed.
PROMISSORY NOTES. 423
494. In general, the rights of the original parties to a
negotiable instrument, such as bills of exchange, bonds and
notes are determined by the law of the place where they are
made, unless it is stipulated that it shall be paid elsewhere.®
And the law of the place, where payment is to be made, will
govern the measure of damages, or the amount of the recovery.’
And if suit is brought on a foreign bill of exchange, if the law
of the State where it was made is not pleaded and offered in
evidence, the court will presume that the common law is in
force there, and apply its rules'to the questions arising in the
ease.’ But if the bill is drawn in England and payable in the
currency of that country, and the plaintiff bring suit on the
bill in this country to recover for a breach of the contract, a
difficult question at once arises as to the measure of damages.
+ Dunn v. Clement, 2 Ala. 392; Hollenback v. Wilbard, 3 Il. 465; Col-
lins v. Burkam, 10 Mich. 283; Ballard v. Webster, 9 Abb. N. Y. 404.
4 Murry v. Gibson, 2 La. Ann. 311; Roberts v. Williams, 5 La. 370-379.
s Murry v. Gibson, 2 La. 311.
Arizona: Ten per cent. where no rate is agreed upon. Contract
valid for any rate. Compiled law, 1871, p. 538.
California: Ten per cent. Parties may contract for any rate, and even
for compound. Judgments can only draw seven per cent. under any
circumstances. Civil code, Sects. 1917-1918-1919-1920.
Connecticut: Seven per cent. On contract for highér rate, principal
can only be recovered with seven per cent. Res. of 1875, p. 351.
Delaware: Six per cent. Whoever contract for more, forfeits a sum
equal to the amount loaned, half to the State and half to the Prosecutor.
Res code, 1852, p. 183.
District of Columbia: Six per cent. A contract for a greater amount
is void and subject the party to a forfeiture of triple the amount otf the
money lent or contracted for, one-hali to go to the United States and the
other to the person who shall sue.
Florida: Six per cent. where there is no agreement for a higher rate.
Parties may contract for eight per cent. A contract for higher rate is
424 LAW OF DAMAGES.
But it is now pretty generally settled that where payment is
to be made in the currency of a foreign country, its amount is
to be computed in the currency of the United States by ascer-
taining what sum the standard coin of one will produce of
equal weight and fineness in the currency of the other. But
where a plaintiff comes from another country into the courts
of the United States to enforce the payment of money, which,
if paid abroad when they were due, would be paid in currency
equal to gold when gold is at a premium here, our courts will
not add to the nominal amount a sum sufficient to enable him
to replace it in gold in the place where it is payable. If the
debt was payable in dollars, the plaintiff, like a citizen, could
recover the nominal amount of dollars and interest only. If
the debt is for so many pounds sterling, the recovery can be
had for that sum only, converted into dollars at the rate which
the pound sterling bears to the dollar, without any premium
or regard to the rate of exchange between the two countries, *
owing to the want of a specie currency here. But where a bill
is drawn in one State, payable in another, with the current
rate of exchange in the State in which it is drawn, the holder
may recover the different rate of exchange between the two
places.” And it may be remarked generally that the only
.° Swanson v. Cook, 45 Barber 574; Rice. v. Ontaco Steamboat Co, 56
Barber 384; Gutacap v. Wamluse, 2 McClain, 581; Bank of Illinojs v.
Brady, 3 McClain 268.
void. Taking of usury is indictable and punishable by fine and for-
feiture of all interest. Thompson Digest, p. 234-235.
Georgia: Seven per cent. where there is no agreement to the con-
trary. Parties may contract for any rate in writing. Code 1873, p. 362.
Illinois: Parties may contract for any rate not exceeding ten per cent.
Where no rate is specified six per cent. can be recovered. Res. stat.,
1874, p. 614.
Indiana: Six per cent. where there is no agreement. Parties may
PROMISSORY NOTES. : 425
damages that can be recovered on bills of exchange and
promissory notes is the principal, with legal interest, and ex-
pense of protest, and in some instances the difference in ex-
change, and this rule is strictly adhered to in case of obliga-
contract for any sum not exceeding eight per cent. Act of 1879, p. 43.
Iowa: Six per cent. in want of an agreement for a different rate.
Parties may contract for any rate not exceeding ten per cent. Usury
paid may be recovered back. Code 1873, p. 377-378.
Kentucky: Six per cent. in absence of expressed agreement. Parties
may contract in writing for any rate not exceeding ten per cent. Usury
is attended with a forfeiture of all interest. Gen. stat., 1873, p. 562-565.
Louisiana: Five per cent. in absence of a contract for a greater rate.
Parties may contract for any sum not exceeding eight per cent. Bank
rates, six percent Usury forfeits all interest. Civil code, p. 393.
Maine: Six per cent. in absence of any agreement. Res. st., 1871, p.
391. /
Maryland: Six per cent. Usury forfeits only the excess over legal
rate. Code 1865, vol. 1, p. 696.
Massachusetts: Six per cent. Parties may contract in writing for any
rate. Sup. gen. statute, 1873, p. 539.
Michigan: Seven per cent. Parties may contract for any rate not ex-
ceeding ten per cent. Contract only void for excess. Compiled law of
1871, p. 540.
Montana: ‘Ten per cent. Parties may contract for higher rate. Cod-
ified statute, 7 Sess., p. 497-498.
Minnesota: Ten per cent. Parties may contract in writing for any
rate not exceeding twelve per cent. Stat. at Large, 1873, p. 711.
Mississippi: Six per cent. Parties may contract in writing to pay any
rate not exceeding ten per cent. Res. code, 1871, Sects. 2279-2282.
Missouri: Six percent. Parties may agree upon any other rate not
* exceeding ten per cent. Usury works a forfeiture of the interest to the
county where thesuit is brought. W., Mo. stat., vol. 1, p. 782-783.
New Hampshire: Six per cent. Party, taking more forfeits three
times the amount taken.
New Jersey: Seven percent. The amount of the principal can only
be recovered. Res st., 1874, p. 356.
New York: Seven percent. All contracts for more are void. Usury
426 \ LAW OF DAMAGES.
tions to pay money.’ It is true, as we have already said, that
the non-payment of money when due some times causes the
creditor to lose a sum far beyond the legal interest on- the
money due. He may, by reason of the failuré of the defendant
to pay the money pursuant to the agreement, be put to great
works a forfeiture of principal and interest. Statute at Large (Ed-
monds), vol. 1, p. 725-726.
North Carolina: Six per cent. Eight per cent. may be contracted in
writing for theloan of money. No’ higher rate can be recovered. Batts’
Revival, p. 825.
Nebraska: Ten percent. Parties may contract for any rate not ex-
ceeding twelve per cent. Usury forfeits interest. Gen. stat., p. 446-447,
(1873).
Ohio: Six per cent. Excess over this paid may be recovered back.
Res. st., p: 724-744.
Pennsylvania: Six per cent. Usury cannot be recovered. If paid it
may be recovered back. Canal and railroad companies may borrow at
a higher rate. " See Purd. Digest, p. 803
Rhode Island: Six per cent. when there is no other specified amount.
Gen. stat. (1872), p. 270.
South Carolina: Seven percent. It is thought a person may contract
for a higher rate, but this is doubtful. Res st. (1873), p. 318.
Tennessee: Six per cent. Parties may contract for any rate not ex-
ceeding ten per cent. Party taking more is liable to a penalty of one
hundred dollars. Act 1869-70, chap. 69, sects. 1, 2, 3, 4.
Texas: Eight per cent. Parties may agree upon any rate not exceed-
ing twelve per cent. Pascol Digest, p. 665-666.
Vermont: Six percent. Interest paid in excess of this may be recov-
ered back. Usury forfeits excess over legal interest. - Gen. st. 1863, p.
507-579. e
Virginia: Six percent. Parties may contract for eight per cent. in
usury. Excess of these rateg cannot be recovered. Banks may take in-
terest on loans at the rate of two-thirds of one per cent. for thirty days,
and this may be recovered in advance. Code (1873), p. 977.
Wisconsin: Seven per cent. “Parties may contract for any rate not
exceeding ten per cent. Party taking more is liable for three times the
PROMISSORY NOTES. 427
expense and involved in serious litigation, and be compelled
finally to take the benefit of the bankrupt law. But the law
has fixed his damages, and beyond that he cannot go. The
reason for the rule is that it is generally supposed that money
is worth the legal interest, and no more. And the further fact
‘that it is impossible to know what may result from the non-
payment of money, it is beyond the comprehension of man to
tell what the creditor will losé or how much he may be harrasred
with law suit, but the extent of his recovery is marked out,
and beyond that he cannot recover.’
495. Bills and Notes Transferable. Bills of exchange and
promissory notes are generally transferred by indorsement be-
fore they are due, but this is not always the case, for in the
meager settled districts and territories of the West notes and
bills are frequently transferred after muturity. There is a
very important difference in the effect of the transfer of a note
before maturity and afterwards. The bona fide holder of a note
negotiable by the law merchant, indorsed to him_ before
maturity, takes it free from all equities existing between his
assignor and the maker, save what appear on the face of the
note.’ This rule is established for the purpose of facilitating
trade and commerce, and rests on the theory that when John
Smith gives his promissory note to James Jones, promising to
2 Sedgwick on the measure of damages, 278 to 288; Field on the law of
damages, 190 to 230, and authorities cited.
1] Parson on contracts, 254; Brown v. Davis, 3 J. R. 82; Hall v. Wil-
son, 16 Barber, 548; Fletcher v. Gushee, 32 Me. 587; Grayson v. Lee, 9
Gill 138; Kohlman v. Ludwick, 5 La. Ann. 33.
excess which he recovered back in one year afterwards. Taylor’s stat.,
‘Wis , (1871) p. 838.
West Virginia: Six per cent. generally. Contracts for more are void.
Party taking more forfeits double the amount taken. Code 1860, p. 624--
625,
428 LAW OF DAMAGES.
pay him or order one thousand dollars, that the promise is in
the alternative, and the note is a promise to pay Jones or any
one else to whom he may direct the payment tobe made. And
when Jones indorses the note to Henry Ray he orders Smith
to make payment tohim. And when Smith is finally sued by
a remote indorser, he will not be permitted to defendon the
ground that Jones was indebted to him at the time of the as-
signment, or that there was a failure of consideration, because
the holder can say you promised to pay me. When the note
is transferred by indorsement and delivered to the purchaser,
if the assignor has not written, the purchaser may write over
the name of the indorser, “Pay the contents of this note to ——
or order.” The drawee of a bill of exchange after he has ac-
cepted it stands bound to the same as the maker of a promis-
sory note is bound. In fact, in law, it is treated as his promis-
sory note. When the payee indorses a promissory note or bill
of exchange, ‘he enters into a contract with the indorser that
if the maker is called upon by the holder and fails on demand
to pay according to contract, that hé will pay the same. And
if demand is made and notice of non-payment given to the in-
dorser, the holder may sue the maker and indorser together or
separately at his option. In such suits he can recover the
amount of the note or bill, with interest. And where the in-
dorser is sued on his endorsement and compelled to pay costs,
he cannot recover those costs against the maker, as he should
have paid the note without suit. He can only recover as dam-
ages the amount of the note with interest and expense of pro-
test.?, And this is the rule that governs the measure of dam-
ages where an acceptor of a bill with funds in his hands has
failed to pay the acceptance. “If suit is brought against the
drawer and costs paid by him, the acceptor is not liable there-
for.”* “Nor is the indorser of a bill liable to the acceptor for
? Simpson v. Griffin, 9 Johns 131; Steel y. Snyder, 2 McCord 459.
“ Barnwell vy. Mitchell, 3 Conn. 101.
PROMISSORY NOTES. 429
the costs of suit by the holder against him.”* The accommoda-
tion acceptor can, however, recover costs of the drawer, and he
may also recover costs against the maker.
496. Statute Law Making Note Negotiable. In quite a num-
ber of the States promissory notes not negotiable by the law
merchant are made assignable so as to vest the absolute title
in the assignee, and he can sue on it in his own name. The
assignee, as a rule, takes the note subject to any set-off or other
defense that the maker of such note may have against the as-
signor. Such assignee having used due diligence in trying to
make the money from the maker, may then have hisactionon the
indorsement against hisassignor.t And his measure of damages
will be the amount paid for the assignment, together with in-
terest and costs of the suit against the maker. The amount of
the note is prima facie evidence of the price received by the
assignor, but he may show in defense that it was less.’
* Bangor Bank v. Hook, 5 Greenleaf (Me.) 174.
5 James v. Brooks, 4 Taunt 464; Hubble v. Brown, 16 Johns 70; Baker
v Martin, 3 Barber 634; Field on law of damages, 220.
‘ Due diligence see Adam v. Beard, 1 Black 191; Merriman v. Maple, 2
Blackf. 552; Kelsey v Ross, 6 Black 536; Dorsey v. Hadlock, 7 Black 349;
Clark v. Spears, 8 Blackf. 302; Watson v. Robinson, 8 Black 386; Black v.
Wilson, 7 Black 552; Harold v. Scott, 2 Ind. 55; Spears v. Clark, 3 Ind.
296; Zenkerd v. Newkirk, 12 Ind. 544; Croft v. Dodd, 15 Ind. 380.
5 Young v. McCrary, 2 Black 243; 1 Black 191; Lee v. Pile, 37 Ind. 107;
Harris v. Pierce, 6 Ind. 162; Vase v Hurst, 13 Ind. 551; Roberts v. Mas-
ter, 40 Ind. 461.
i
CHAPTER XXXI.
PRINCIPAL AND SURETY.
Surety DEFINED. StTatutTeE oF Fraups. THE SuRETY ON
BOND. ON EXECUTION OF THE AGREEMENT. DEARDORFF V.
ForsMAN. DISCHARGE OF SURETY BY ALTERATION OF INSTRU-
MENT. DISCHARGE OF SURETY BY THE CONDUCT OF OTHER
PARTIES. RELEASE OF PRINCIPAL WHEN DISCHARGE OF SURE-
TY. RELEASE OF MORTGAGE PROPERTY WHEN DISCHARGE OF
suRETY. NoricE To sUE. THE DAMAGES. PAYMENT. SuB-
ROGATION.
497. Surety Defined. A surety is one who engages to be
answerable for the debts, defaults or miscarriages of another,
or who undertakes to do some act in the evént of the failure of
another to do it... At common law it was not necessary that
the contract of surety should be in writing in order to charge
him. This being the case, the statute, 29, Charles II., chapter
3, commonly called the statute of frauds, was passed. The
fourth section of that statute, so far as is necessary to be noticed
in this connection, was as follows, viz.: “No action shall be
brought whereby to charge the defendant upon any special
é
' Burrell’s law dictionary.
PRINCIPAL AND SECURITY. 431
promise to answer for the debts default or miscarriage of an-
other person unless the agreement upon which such action
may be brought, or some memorandum or note thereof shall be
in writing, and signed by the party to be charged, or by some
person thereunto by him lawfully authorized.” This section
has been, in substance, re-enacted in every State in the Union.
It forbids the bringing of an action on any agreement to an-
swer for the debt, default or miscarriage of another, unless that
agreement is in writing and signed by the party to be charged
or some one by him thereunto lawfully authorized. A con-
tract in parol, made since the enactment of this statute, to an-
swer for the debt, default or miscarriage of another, is not. ille-
gal or void, but no action can be brought upon it. In the ma-
jority of cases it is true that this amounts to the Same thing as
if the contract had been declared illegal, but in other cases it
does not. And it may be laid down as a general rule that
where the contract has been executed on both sides, the statute
will not in any manner affect the relation of the parties. If
the surety pays money upon an unwritten promise, he can re-
cover the amount so paid, with legal interest, from the princi-
pal.?
498. The Execution -of the Agreement. Before a surety can
be held responsible, the instrument or agreement must be exc-
cuted. To execute a written agreement is to sign and deliver
it? Questions in relation to the execution of written iistru-
ments are frequently brought before the courts in cases where
the principal has procured the signatures of certain sureties to
an agreement under the promise that he would get other sure-
ties to sign with them, and then deliver the instrument with-
2» Shaw v. Woodcock, 7 Barn & Crees 73; McCue v. Smith, 9 Minn. 252;
Crane v. Gough, 4 Md. 316, Pamle v. Gunn, 4 Bing. N. C. 445; Andrews
y. Jones, 10 Ala. 400; Watrouse v. Clark, 7 Conn. 224; Craig v. Vampelt,
3 J.J. Marsh (Ky.) 489.
3 Peppers v. State ex rel, Harvey, 22 Ind. 399.
432 LAW OF DAMAGES.
out procuring the additional names. “The law may now be
considered pretty well settled that where the securities’ names
are procured in this way and there is nothing on the face of
the agreement indicating that other co-sureties were expected
to sign or become parties to the agreement, and no fact is
brought to the knowledge of the obligee before he accepted the
instrument calculated to put him on his guard upon that
point, and which would naturally have lead a prudent man.
interested in the opposite direction to have made inquiry be.
fore accepting the instrument or surety, the fault cannot be
attributed to the obligee.* This rule rests upon equitable
grounds, and is maintained upon the principle that he who,
by his acts, enables one to perpetrate a fraud upon another must
4
suffer rather than an innocent man.®
499. Deardorf’ et al. vs. Forsman. This case was an action
brought upon a promissory note. The sureties answered,
first, that the principal, who was insolvent, applied to them at
the date of the note for their signatures with him as his sure-
ties to the plaintiff, which they refused to sign; that he fraud-
ulently represented to them if they would sign the note he
would procure as co-sureties with them eleven other responsi-
ble men, who were named, and that he would not deliver the
note to the plaintiff until such signatures were procured. The
court below sustained a demurrer to the answer and the sure-
ties appealed. In the upper court it was contended that the
contract was not binding upon the appellants, for the reason
that the note was delivered to the principal to hold as an
escrow and to be delivered.on the happening of a contingency
or the procuring of the additional signatures. The court, in
commenting upon the question, said: “There are but two
* Peppers v. the State, 22 Ind. 399.
° Deardorff v. Forsman, 24 Ind. 481.
PRINCIPAL AND SURETY. 433
parties to, the instrument, andso long as it is held by the princi-
pal it cannot be said to be delivered for any purpose, for it re-
mains still in the hands of the party who is only to be bound
in any manner upon its delivery to the other. And where
there. is no delivery of the instrument by one party executing
it, it cannot be said to be held as an escrow. Can a delivery
then be made to the principal as the agent of his surety for
any other purpose than an unconditional delivery to his
obligee? The interest of the principal is to get the obligee to
accept the instrument at the earliest moment and with the
least number of sureties. The law takes notice of the fact that
it is not pleasant to solicit one to become security for any
amount, and for this reason that it is to the interest of the prin-
cipal to avoid this unpleasant task as much as possible. On
the other hand, the interest of the surety requires that the in-
strument shall not be delivered until his liability has been re-
duced. by the execution of the instrument by his co-sureties. '
But it is a well settled rule of law that he who has an interest
in the doing of a particular act cannot accept an agency in the
same manner for others, where the interest is adverse to his.
A person will not be permitted to assume an agency for
others when the interest of his principal would be in direct
conflict with his personal interest.” Therefore, the principal
cannot hold the instrument as an escrow for the: surety. The
delivery of the instrument by the sureties after placing their
names upon it to the principal authorizes him to deliver it to
the obligee, for such is the natural channel through which the
paper would pass in reaching the obligee, and a delivery by
him will bind the sureties. The ruling below was confirmed.’
* Deardorff and others v. Forsman, 24 Ind. 481; Peppers v. the State,
22 Ind. 399; Foley v. Cogill, 5 Blackford 18; the State v. Chisman, 2 Ind.
126; Wright v. Shelby & Co., 16 B. Mor. 5; 7 Ind. 600; 6 Ind. 183; 8 Ind.
256; Worrall v. Munn, 1 Seld. 229; Ward v. Lewis, 4 Pick. 518; Fairbanks
v. Metcalf, 8 Mass. 230; Babcock v. Steadman, 1 Root Conn. R. 87; 3 Barr
(Pa.) 808; 2 Jobns R. 248; 34.N. H. 460; 18 Pick. 75 Palmer v Rich
434 LAW OF DAMAGES.
500. But where an instrument is executed by sureties
and delivered to one of their number to keep until certain addi-
tional co-sureties shall sign it, the instrament until so exe-
cuted is held as an escrow. And where the instrument con-
tains the names of the parties who are to execute it, or the
obligee has notice sufficient to put him on the inquiry
in either of these cases, the delivery Will not bind the sureties.”
501. Discharge of Surety by Alteration of the Contract. The
question of -the liability of the surety on instruments in
writing, where they have been altered or time extended after
execution, frequently arises between parties, and upon this
point the authorities are not harmonious. But the rule laid
down by that able commentary, Judge Story, has been generally
adopted in this country. He says: “Nothing can be clearer
both on principle and authority than the doctrine that the lia-
bility of the surety is not to be extended beyond the terms of
his contract. To the extent and in the manner and under the
circumstances pointed out in his obligation he is bound, and
no further. It is not sufficient that he may maintain no injury
by the change in the contract, or that it may even be for his
benefit. Hehas aright to stand upon the very terms of his
contract, and if he does not assent to any variation that is made
1E. L. & E. 529; Leaf v. Gibbs, C. & P. 466; Andre v. Dixon, 5 L. & Eq.
R. 512; Russell v. Longstiffe, 2 Doug 514; Fullerton v. Sturges, 4 Ohio
st. R. 529; Parson on bills and notes, 111; Miller v. Parker, et al , ¥ Met.
(Ky.) 608; Dixon v. Dixon, 3 Vt. 450; Story Agency, 8. 211; Copeland v.
Mercantile Ins. Co.. 6 Pick. 198; the Utica Ins Co. v. Toledo Ins. Co., 17
Barber 132; 10 Vesey 381; 2 Robinson 556; 19 Barber 595; the State of
Ind. on of Lahey v. Gaston, 32 Ind. 1; Blackwell v. the State. 26 Ind.
204; Webb v. Baird, 27 Ind. 368; the State ex rel. McCarthy v. Peppers)
31 Ind. 37.
* The People v. Boswick, 32 N. Y. 445; the State v. Baldly, 7 Black 355;
Peppers v. the State, 22 Ind. 399.
> Muller v. Stewart, 9 Wheat (U. 8.) 680; Judah v. Zimmerman, 22 Ind.
388, .
PRINCIPAL AND SURETY. | 435
it is fatal,’ and avoids the instrumentastohim. Any material
alteration of the instrument by a party in interest, without
the consent of the surety, will discharge him from all liability
on the instrument.’
502. Discharge of the Surety by Extension of Time. The exten-
sion of time for the payment of money by the payee of a
promissory note has been a great source of annoyance to the
legal profession for centuries. It was held as early as the reign
of Edward IV. that where the creditor without the consent of
the surety gave time to the principal debtor by agreement, even
without consideration, that it discharged thesurety. And this
rule seems to have been well settled in England for centuries.”
But in more recent times the doctrines sprang up, as is now
established, that to discharge the surety the agreement to give
time must be supported by a consideration. And it may now
be considereed as settled by the weight of authorities that in
order to discharge the surety by extension of time it must ap-
pear that there was an agreement to extend the time to a definite period,
and that the agreement was based on a valuable consideration. But an
agreement to pay the same rate of interest as specified in the
instrument, is not a sufficient consideration to support such a
contract. But an agreement to pay the same interest as is
specified in the instrument-in advance, where no such provi-
sion appears on the face of the agreement, is generally held to
be sufficient consideration to uphold such an agreement.* The
payment of usurious interest in advance constitutes a sufficient
3 Kountz v. Hart, 17 Ind 329; Holland v. Hatch, 11 Ind. 479
2 Spence’s Eq. J. 638.
3-Abel v. Alexander et al., 45 Ind 523; Bowan v. Houk, 1 Black 392;
Naylor v. Moody, 3 Black 92; Conan v the State, 5 Black 367.
4 Bagley v. Bazzell, 19 Maine 88; Lime Rock Bank v. Mallett, 34 Me.
547; S.C 42 Me. 349; Andrews v. Mecmett, 58 Maine 539; Hunter y. Pos-
tlewaite, 28 Iowa 427; Gahn v. Niuenwise, 11 Wend. 317.
436 LAW OF DAMAGES.
consideration to support an agreement to extend the time of
payment of the principal.’ An agreement to extend the time of
payment to a definite time of any instrument promising to pay
money upon a valuable consideration without the consent of
the surety, will discharge him from liability.’ But the giving
of time without consideration will not discharge the surety, al-
though the surety had no notice of such agreement. As a
general rule, a surety is liable to the creditor in the same man-
ner and to the same extent as the principal debtor, and he may
set up in defense any matter which ought in equity to go to
his personal exoneration.
508. The Discharge of the Surety by the Conduct of the Other
Parties. It may be laid down as a general rule that no act of
the other parties to a contract will discharge a surety from his
obligation, unless it in some way impairs his power of recourse
against the principal either through a bill in equity or pay-
ment of the debt and substitution to the rights of creditor. If
his recourse against the principal remains the same as it was
at the time he executed the instrmuinent, his right to exoner-
ation must fail." Theréfore, where a creditor at the time he re-
leases a principal reserves his remedies against the surety,
such'release amounts toa covenant not to sue only and does not
discharge the surety.‘
® Harbert v. Dumont, 3 Ind. 346; Redman vy. Deputy, 26 Ind 338; Cal-
vin v. Wiggom, 27 Ind. 489; Cross v. Wood, 30 Ind. 378,
® Campbell v. Gates, 17 Ind. 126.
* Morgan v. Smith, 70 N. Y. 537; Bouetler v. Stubles, 18 Vesey 20-22;
Burke’s case cited, ex-party Gifford, 6 Vesey 805-809; Weeb v. Hewett, 3
Kay & J. 338; Kearsly v. Cole, 16 M. & W. 126; Prout v. the Branch
Bank,6 Ala 309; 2 Leading cases in equity, part ii, 353-383; 2 Am. ed.;
Price v. Barker, 4 Ellis & Blackburn 769; Viele v. Hoag, 24 Vt, 46.
* Baleson v. Gosling, Law Rept. 7, Com. Pl. 9; Hall v. Thompson, 9 Up.
Can. C. P. R. 287; Wood v. Britt, 9 Grant Ch. R. 142; Bell v. Manning,
11 Grant Ch. R. 452; Greeso v. Wynn, Law Rept. 4 Ch. Appl. 2047.
PRINCIPAL AND SURETY. 437
504. Thus where the defendant pleaded that his principal
with whom he was jointly bound having been, as he claimed,
released by agreement under seal, which obliged the plaintiff
not to sue him, and if he did the agreement thus made should
be a sufficient release and discharge to all intents and purposes
both at law and in equity to and for all the debtor and his
assigns, etc., it was held that the surety was not discharged.’
Since the determination of this case, we believe there has not-
been a single decision in the courts of England opposite to the
principle it affirms.’ And in the courts of the different States
of this country we believe the sanie rule is adhered to without
exception.’
¥
505. When the Security will be Discharged. As a general rule
the release of one of several joint debtors, or joint and several
* Dean v. Newhall, 8 J. R. 168
6 Farrell v. Forest, 2 Saund. 48, note 1.
So strictly are these technicalities adhered to, that no release is allowed.
by implication. It must be the immediate legal result of the terms of
the instrument which contains the stipulation, hence it is that a cove-
nant not to sue or to assert a claim, or in any manner to hold liable one
joint debtor, etc., though it operate between the immediate parties, does
not extend to others. Baily v. Berry, 8 Am. L. Reg. 270.
? Baily v. Berry, 8 Am. Law Reg. 270McLelland v. Cumberland Bank,
24 Maine 566; McAllister v. Sprague. 34 ib. 296; Walker v. McCullough;
4 Greenl. 421; Tuckerman v. Newhall, 17 Mass. 581; Shaw v. Pratt, 22.
Pick. 305; Smith v. Bartholomew, 1 Met. C. 276; Brown v. Marsh, 7 Vt.
327; Durell v. Wendell, 8 N. H. 369; Snow v. Chandler, 10 ib. 92; Crane;
adm., v. Alling, 3 Green N. J. 423; Catskill Bank v. Messenger, 9 Con
38; Rawly v. Stoddard, 7 Johnson 207; Couch v. Mills, 21 Wend. 424;
Bronson v. Fitzhugh, 1 Hill 185; Frink v. Green, 5 Barber 455; Alesworth
vy. Brown, 21 Ind. 270; Hubble v. Carpenter, 5 N. Y. 171; Morgan v.
Smith, 70 N. Y. 537.
Where a release of one of several obligors showed upon its face and in
its connection with the surrounding circumstances that it wasnotithe
intention of the parties to release the co-obligors, and the court was con-
vinced that the whole scheme of procuring a separate release of one of
the obligors was a plan of all for escaping full payment, the instrument
was construed as a covenant not to sue and the co-obligor not discharged. .
Parmalee v. Turrace, 44 Ill. 405. %
438 LAW OF DAMAGES.
debtors, is a release of all, and a full and final satisfaction of ©
the whole debt.2, And’ a release that does not discharge the
whole debt will not exonerate the security. No agreement
will ever be construed into a release unless it gives the cov-
enanter a right of action which will precisely countervail that
to which the party is liable, unless, also, it was the intention
that the last instrument should defeat the first.
506. Construction. In constructing an agreement of re-
lease the court will be confined to its terms and within the
considerations. No technical effect or any effect beyond what
was intended by the parties can be inferred or allowed by im-.
plication. It has long been the judicial rule for courts to re-
strain such release within its terms in accordance with the in-
tent of the parties, and to give effect to it only within this
scope.* The intention of the parties is alone regarded, and the
old legal maxim in construction is applied that where a par-
ticular purpose is to be accomplished and language which ex-
presses it is clear and certain no general words subsequently
used in the same agreement shall extend the meaning of the
parties... Thus where a receipt had been given by a creditor to
one of his joint debtors, which receipted that the debtor had
paid a certain sum in full of his half of the debt due jointly
from him ahd another, and which was to be his discharge itt
full for the debts and costs, but no discharge of his co-debtor,
| American Bank v. Doolittle, 14 Pick. 123; Tuckerman v. Newhall, 17
Mass. 581; Ward v. Johnson, 13 ib. 148; Elliott v. Holbrook, 33 Ala. 659;
Vandever v. Clark, 16 Ark. 331; Rawly v. Stoddard, 7 Johns 207. ~
A release of one or two joint and several obligors is a release of both,
but a covenant not to sue one of two obligors cannot have the effect of a
release of both. Crane v. Alling, 15 N. J. L. (3 Greenl.) 423.
2 Walker v. McCullough. 4 Me. 421.
3 Druell v. Wendell, 8 N. H. 369.
“ Burke v. Noble, 48 Penn. st. ee Rapp v. Rapp, 6 Barr 45; Pierce v.
Sweet, 9 Carey 151.
5 Baily v. Berry, 8 A. L. Reg. R. 270; Thorp v.Thorp, 1 Lord Raym. 235.
PRINCIPAL AND SURETY. 439
it was decided that this could not be pleaded as a release by
the other judgment debtor, as it was the intention of the par-
ties that his liability should still remain.‘
507. Discharge of a Co-Surety. It may be laid down as a
general rule, upheld by the decided weight of authority, that
the obligation of one of two co-sureties is to pay the whole
debt. If he does so, he may recover of his co-surety one-half.
If he pays less than the whole debt, he can only recover from
the co-surety the amount which he has paid in excess of the
moiety. Therefore, when a co-surety has by the.conduct of the
creditor been released from liability, another co-surety will be
held exonerated only as to so much of the original debt as the
one so discharged could have been compelled to pay. If, how-
ever, in the discharge of the co-surety the contract is materially
altered as a rule, the surety will be discharged.’
508. The Relation of the Parties Remains the Same After Judg-
ment. The relation of the parties to a promissory note or an
agreement to pay money continues after judgment. And
whatever act that will discharge one of the joint makers of a
promissory note or other agreement to pay money will dis-
charge a party toa judgment rendered on that note or instiu
ment. Thus, where the plaintiff who held a judgment against
6 McAllister v. Sprague, 34 Maine 297; see also Durell v. Wendell, 8 N.
H. 369.
Where the release pleaded as a discharge to all has been given to one
only, it must be a technical release expressly stating the cause of action
to be discharged, with all conditions or exceptions. Fitch v. Sutton, 5
East 232; Rawly v. Stoddard, 7 Johns 207; Dizing v. Baily, 9 Wend. 336;
Shaw v. Pratt, 22 Pickering 305; Mason v. Jewett, adm., 2 Dana 107.
” Morgan v. Smith, 70 N. Y. 537; Brandt on Sureties, Sect. 383; Jamison
v. Grovenor, 48 Ala. 390; State v. Matson, adm, 44 Mo. 305; Schock v.
Miller, 10 Pa. st. 401; Klingensmith v. Klingensmith, e’xr, 31 Pa. st. 460;
see contrary to this Story v. Johnson, 32 Ind. 438; Thompson v. Adams,
1 Freeman Ch. (Miss.) 225; Stockton v. Stockton, 40 Ind. 225.
440 LAW OF DAMAGES.
two defendants for a large-sum of money agreed with one of~
them on his payment of the moiety of the whole, that they
would henceforth pursue the legal and equitable remedies on
said judgment against the other defendant alone and note
against the one who had paid the moiety looking to the delin-
quent party alone for a full and final payment and satisfaction
of the said judgment without, however, intending to prejudice
or interfere wilh the rights and liabilities of the said judgment
defendants to each other on account of such judgment. The
court said: ‘The general proposition is familiar that'the release
of one of several joint debtors is a release of all others, and the
appellant contends the proposition is applicable in this case.
This is not technically a release.” By its terms it is a mere cov-
enant not to pursue one of the parties, and it is made clear by
the words that it was not intended to release the other. It is
only by implication that it would be construed to release the
party who has paid a portion of the money. The cases seems
to be uniform that such an instrument would not release. the
other, “The sole object which courts can have in the con-
struction of instruments would be outraged by declaring this
to be a release of both debtors. The law should not be subject
to such reproach.” |
And this rule applies in its broadest sense to the relation
of principal and surety. The surety is both in law and in
equity entitled to the same rights, and will be discharged by
' Aylesworth v. Brown, 31 Indiana 270; see also Baily v. Berry, 8 Am.
L. Reg., p. 270; 1 Parson.
* Commercial Bank v. Western Reserve Bank, 11 Ohio 444; Brown v.
Ayer, 24 Ga. 288; Commonwealth v. Miller, adm., 8 Seg. & Rawle 452;
May v. Pettengill, 3 Minn. 217; Chambers v. Cochran, 18 Ia. 159; Rice v.
Morton, 19 Mo 263; Davis v. Mitchell, 1 Freeman’s Ch. (Miss.) 505; Bangs
v. Strong, 7 Hill (N. Y.) 250; Curan v. Colbert, 3 Kelly (Ga.) 237; Brown
v. Ex’rs of Riggins, ib. 495; Delaplain v. Hitchcock, 4 Ed. Chaney 321;
Allison v. Thomas, 29 La, An: 782.
PRINCIPAL AND SURETY. 441
the came act of the creditor after as before. the judgment.’
There are a few cases that hold that the character of the surety
as such becomes merged in the judgment, and that he thence-
forth becomes a principal and is not entitled to the right of
surety. But there is but little conflict upon the subject.‘
509. Property Mortgaged or Pledged by One for the Debts of An-
other Stands as Surety. The law is well settled that where one
mortgages or pledges his property, either real or personal, to
answer for the debts, default or miscarriage of another person,
that such property will occupy the position of a surety, and
that anything that will exonerate a personal security will
‘discharge the property.. And this rule applies to a married
woman who has mortgaged or pledged her real or personal
property to secure the debts, etc., of her husband.*
510. Surety Discharge by Releasing Levy on Property. If the
creditor recovers a judgment against the principal and surety,
or against the principal alone, and causes an execution to be
issued thereon and levied upon real or personal property of the
4 McNutt v. Wilcox, 1 Freeman’s Ch. (Miss.) 116; Bay v. Talmadge, 5,
Johns’ Ch. 305.
§ Robinson v. Gee, 1 Vesey, Sr., 251; Royal Canadian Bank v. Payne
19 Grant Ch. R. 180; Christian v. Brown, 16 Iowa 130; Denson v, Gibson,
24 Mich. 178; Joseph v. Heaton. 5 Grant Ch. 636; Ryan v. Shawneetown,
14 Ill. 20: Lord Harberton v. Bennett, Beatty (Ir. Ch.) 386; Rowan v.
Sharp’s Rifle Co., 33 Conn. 1; Union Bank v. Governor, 10 Smedes &
Mar. (Miss.) 333, Baker v. Ball, 1 Simons(N.S.) 29; White v. Ault, 19 Ga.
551,
® Johns v. Reardon, 24 Mich. 187; Agnew v. Merritt, 10 Minn. 308; Wal-
lace v. Hudson, 37 Texas 456; Wolf v. Ranning, 3 Minn. 202; Spear v.
Ward, 20 Cal. 659; Newcomb v. Gahn, 3 Paige 614; Staniford Banking
Co v. Ball, 4 De Gix Trib. and J. 310; Gahn v. Numenz, 11 Wend. 312;
Knight v Whitehead, 26 Miss. 245; Vartie v. Underwood, 18 Barber 561;
Smith v. Townsend, 25 N. Y 479; Bank of Albion v. Burns, 46 N. Y. 170;
Coats v. McKee, 26 Ind. 223; Wilcox v. Todd, 64 Mo. 388; Burns v. Coats,
7N, C. 575.
\
442 LAW OF DAMAGES. --...
principal subject thereto, and afterwards releases it from .the.
levy and it is lost as a security, the surety is discharged to the
extent of the injury. This rule is based upon the principle.
that the surety is entitled to the benefit of all the securities.
which the creditor, after the surety becomes bound or at any
time, may obtain for the payment of the debt. The creditor
is a trustee to retain and safely keep all the securities that
comes into his hands for the benefit of all the parties con-
cerned.”
511. Release of a Lien on Property will Discharge the Surety.
“ A creditor who has the personal contract of his debtor with
surety, and has also or afterwards takes property from the prin-
cipal as a pledge or security for the debt, is to hold the property - ‘
fairly and impartially for the benefit of the surety, as well as
himself, and if he parts with it without the knowledge or
against the will of the surety he shall lose his claim against
the surety to the amount of the property so surrendered.”
512. Notice to Sue. It is provided by the statutes of most
of the States that if the surety notifies the creditor in writing ,
7 Dixon v. Ewing, adm., 3 Ohio 280: Houston v. Hurly, 2 Del. Ch. R.
247; Cooper v. Wilcox, 2 Devereaux & Bat..Eq. 90; Marby v. Dixon, 12
Cal. 561; State Bank v. Edwards, 20 Ala. 512: Spence v. Thompson, 6 Irish
com. law 537; Winston v. Yeargin, 50 Ala. 340; Comstock v. Creon, 1
Robinson (La.) 528; Alexander v. Bank of Commonwealth, 7 J. J. Marsh
(Ky.) 581; Bank v. Fordice, 9 Pa. st 275; May v. Pettengill, 3 Minn. 217;
Shannon v. MeMullin, 25 Gratt (Va.) 21
1 Stewart v. Davis, Exe. 18 Ind. 74; alee v. Briggs, 8 Pick. 122; 25 Ind.
374; 29 Ind. 347; 51 Ind 346.
And this rule is extended so far as to exonerate the surety from lia-
bility where the creditor exchange the mortgage or pledged property for
other property of equal or greater value. Savings Bank v. Concord, 15
N. H. 110."
And the rule applies in every instance where the creditor suffers the
means of payment or satisfaction to pass without applying them to the
discharge of the debt and consequent indemnification of the surety.
Perrin v. Fire Ins. Co. of Mobile, 22 Ala. 575.
PRINCIPAL AND SURETY. 443
to sue the principal, that if he fails to do so within a reasona-
ble or specified time, tnat the surety will be thereby dis-
charged.’ But it is well settled that notice in such case must,
in order to avail the surety, be a positive demand to bring suit,
Technical accuracy is not required. It is sufficient that the,
notice is positive and can be clearly understood. The notice
should be given to the holder and equitable owner of the note
on which the strety is liable, although the legal title is in an-
other.’ The giving of the written notice provided by the
statute may be waived by parol. Thus, where the surety noti-
fied the creditor orally to sue the principal and he promised to
do so, the court held that this was a waiver of the written no-
tice.‘
513. Surety on Note Given for Particular Purpose. It may
now be considered well settled that where a surety signs a
negotiable note, with the principal, for a particular purpose,
and it is used by the principal for another ‘and different pur-
pose, and the party taking it has then knowledge of the fact
sufficient to put him on the inquiry, the surety is not bound.
But if he has no such notice the surety will be held liable.’
, Towns v. Riddle, 2 Ala. 694; Shehan v. Hampton, 8 Ala. 942; Hem-
stead v. Watkins, 6 Ark 317; Dorman v. Biglow,1 Fla. 281; Reid v. Cox,
5 Black (Ind.) 312; Craft v. Dodd, 15 Ind. 380; Clark y. McCleas, 9 Ind.
245; Stevens v. Campbell, 6 Iowa 538; Jenks v. Clark, 7 Ohio 72; Bolton
v. Londy, 6 Mo. 46; Payne v. Webster, 19 Ill 103; Strade v. Hington, 9
Post Ala. 334; First, &c., Bank v. Smith, 25 Iowa 210; Nichols v. Me-
‘Dowell, 14 B. Mon. (Ky.) 6; Greenwalt v. Keitler, 3 Pa..st. 264.
? Routon, adm., v. Lacy, 17 Mo. 309; Kaufman v. Wilson, 29 Ind. 504; ’
Rice v. Simpson, 9 Hisk (Tenn.) 809; Baker v. Kellogg, 29 Ohio st. 663.
3 Overturf v. Martin, 2 Ind. 507; Bank v. Munford, 6 Ga. 44; Kelly v.
Matthews, 5 Ark. 223; Adams v. Roane, 7 Ark. 360; Cummins v. Garret-
son, 15 Ark. 132; Driskell v. Board, Conn. 53,,Ind. 532.
* Taylor v. Davis, 38 Miss. 493; Smith v. Clapton, 48 Miss. 66; English
v. Brown, 7 Bush (Ky.) 138; Hamlin v. McCallister, 4 Bush. 418; Simp-
son v. Blunt 42 Mo 542; Gillion v. Ludington, 6 West Va. 128; Baily v.
New, 2 Ga. 214; Davis v. Payne, 45 Iowa 194.
~-5 McWilliams v. Mason, 31 N. Y. 294; Manufacturers’ Bank v. Cole, 39
¢
444 LAW OF DAMAGES.
514. The Damage. Where a surety has been compelled to
pay the debt of his principal, he may recover it back with legal
interest and costs." But he cannot recover extraordinary ex-
penses which might have been avoided by payment of the
money or for remote or unexpected consequences. They are
never considered as coming within the contract. If the surety
by reason of having to pay money for his principal becomes
embarrassed and finally takes the benefit of the bankrupt law
or make an assignment of his property for the benefit of his
creditors, it could not be expected that the principal would in-
demnify him for the consequent misfortune. It is not the
natural or necessary effect of his being a surety, but is occa-
sioned by his undertaking to do what he was not in a condi-
tion to perform.’
515. Payment. The surety has no cause of action against
his principal until he pays a part or the whole-of the debt.
The question as to what shall be considered a payment by the
surety is one not free from difficulty. But it is pretty well
settled that if the surety takes up the original note given by
the principal and himself, and gives his own note negotiable
by the law merchant to the creditor, it will be prima facie evi-
dence of payment.' And where the surety takes up the orig-
Me. 188; Russell v. Ballard, 16 B. Mon. (Ky.) 201; Prescott v. Brinsly, 6
Cush. 233; Conway v. U. 8. Bank, 6 J. J. Marsh (Ky.) 128; Hite v. Camp-
bell, 10 B. Mon. (Ky.) 80; Kimble v. Cummins, 3 Met. 327; Macey v.
Adams, 14 Mass. 327; Riddle v. Bowman, 27 N. H. 236; Apgar v. Hiller,
24.N. J. L. 812; Powell v. Smith, 8 Johns N. Y. 249; Holmes v. Weed, 19
Barber 128.
* White v. Miller, 47 Ind. 385; Burges on Suretyship, 360; Hite v.
Campbell, 10 B. Mon. (Ky.) 80; Kimble v. Cummins, 3 Met. 327; Riddle
v. Rowman, 27 N. H. 987; Apgar v. Hiller, 24 N. Y. L. 812; Powell v.
Smith. 8 Johns N. Y. 249; Holmes v. Weed, 19 Barber 128. ‘
* Haden v. Cabat, 17 Mass. 169; Bishop v. Williams, 2 Fairfield 495.
' Wood v. Waterville, 5 Mass. 294; Marcely, 6 Mass. 143; Johns v.
Johns, i Mass. 359; Butts v. Dean, 2 Met. 76; Seber v. Tupp, 15 M. &
W. 23; 2 Greenleaf evid., sec. 521; Thompson vy. Perrysville, 5 Barn &
Ad. 925; Siieewell v. Day, 45 Ind. 501.
PRINBIPAL AND SURETY. 445
inal agreement and gives his own note to the payee, or delivers
to him the promissory note of a third person, and it expressly
agreed that such note shall be received in full satisfaction of
the debt of his principal, this will be such a payment as will
authorize an action by the surety against his principal.2 And
the surety may pay off the original obligation before it is due
and hold it until it becomes due, and then sue the principal
on his failure to pay when it falls due.’
516. Subrogation. On payment of the debt by the surety
the law gives him the right to the original evidence of debt
held by the creditor, and to any judgment in which .the debt
has been merged, as well as to all the collateral securities held
by the creditor.* By performing the contract of suretyship
the principal obligation is discharged against the creditor and
is kept alive between the debtor, creditor and the surety for
the purpose of enforcing the rights of the latter.
517. Contribution. Where one of several sureties on the
same obligation has paid off the debt, he may, after it becomes
due, bring an action against his co-sureties for contribution.
Andin such cases he may recover such an amount as will make
them equal inloss.* And when any one or more of the sureties
2 De Butts v. Bacon et al., 2 Cush. U. 8S. 391; 6 Cranch 252; Tyner et
al. v. Stoop, 11 Ind. 22; Muldoon v. Whitlock, 1 Cowen 290; French v.
Price, 24 Pick. 13.
3 Armstrong v. Gilchrist, 2 Johns cases 424; Craig v. Craig, 5 Rawle 91;
Jackson v. Adamson, 7 Black (Ind.) 597; 44 Ind. 15; 39 Ind. 16; 33 Ind.
289.
3 Griffin v. Orman, 9 Florida 22; Winder y. Diffenger, 2 Blan. Ch. 166;
Richmnnd vy. Houston, 15 Ind. 134; Coe v. N. J. Mid. R. R. Co., 27 N. J.
Eq. 110; Hough v. tna Life Ins. Co., 57 Ill. 318.
4 Fielding v. Waterhouse, 8 Johns & Spencer (N. Y.) 424; 46 Mo 557.
3 Odine v. Greenleaf, 3 N. H. 270; Juda v. Mieure, 5 Black 171.
* 1
446 LAW OF DAMAGES.
are insolyent, the division is made among those that are sol-
vent.‘
518. A Guaranty Defined.’ A guaranty may be defined to
be a contract to become responsible for the payment of money
or the performance of a duty by another person who is primarily
and properly liable to pay or perform it, or in case of a failure
on his part that the party guaranteeing will himself pay the
debt or answer for the default,’ or an agreement to answer for
the payment of money or the performance of some duty in case
of the failure of the one to do so who is in the first instance
liable for such payment or the performance of such duty.”
518. Surety and Guarantor. There is confusion in the text
books and even in the decisions upon the subject of guarantor
and suretyship. Some times the two things are confounded
and the terms used interchangeably as signifying the same
thing. And, in fact, there is quite a similarity in the nature
of the agreements. They are both contracts to answer for
the ‘debt, default’ or miscarriage of another, but in many
respects they are quite dissimilar. A contract of guarantor is
his own separate contract. It is in the nature of a warranty
by him that the thing guaranteed to be done by the’ principal
‘ Whitehead v. Pitcher, 13 Ind. 141.
But where the surety has paid the debt in real or personal property
the value of the property will be taken as the amount paid in making
the contribution. Jones v. Bradford, 25 Ind. 305.
* Burrell’s Law Dictionary. :
+3 Kent’s com. 12.
If the writer ofa bill of credit state that he will guaranty the payment
of the goods to be afterwards sold to another, or that he will see the goods
paid for, or that he will be surety for the payment, the promise is only
collateral. . The purchaser, under such circumstances, for whose use the
goods are furnished, is himself liable in the first instance, and it is only
after his default that the surety becomes liable. He would only be lia-
ble in suit founded on special contract. Smith v. Bainbridge, 6 Black
(Ind.) 12; Chitty on con., 397.
PRINCIPAL AND SURETY. 447
shall be done. His contract is independent of the principal.
He is not bound like a surety to do what the principal has en-
gaged to do, but only to answer for the consequence of the de-
fault of the principal. The original contract of the principal
is not his contract, and he is not bound to take notice of its
non-performance. In order to bind the guarantor he, as a gen-
eral rule, must be notified of the default of the principal, and,
as a general rule, he cannot be sued with the principal for his ©
engagement, as has already been said it is strictly an individual
contract.’ A surety is bound with his principal as an original
promisor. He is a debtor from the beginning, and must see
that the debt is paid, and is held ordinarily to know every de-
fault of his principal, and cannot escape responsibility for
want of notice or from the fact that indulgence ‘has been given
the principal. His obligation to pay the debt is equally abgo-
lute with that of the principal. And it may be laid down as
a general rule that the mere prolongation of the term of pay-
ment of the principal debtor or of the time for the performance
of his duty will not discharge the surety or guarantor. There
must be another contract substituted for the original contract
or some alteration in a point so material as in effect to make a
new contract without the surety’s consent to produce that re-
sult." As a rule, the same acts that will discharge a surety
from his obligation will discharge a guarantor. For the dis-
cussion of this question see “Principal and Surety.”
519. Damages. The liability of the guarantor will be
measured by that of the principal, and will be so construed
unless a less or greater liability is expressly assumed by the
guarantor. And whateverdamages the plaintiff has suffered by
reason of the default of the principal he can recover off of the
3 McMiller v. B. H. B., 32 Ind. 11; Gaff v. Sims, 45 Ind. 262.
6 Gaff v. Sims, 45 Ind. 262
" Benjamin v. Hillard, 23 How. U. 8. 149.
448 LAW OF DAMAGES.
guarantor. The plaintiff, as a general rule, is entitled to full
compensation for all loss sustained.°
520. Thus, in one case where the principal failed to de-
liver a machine that had been contracted: for, but delivered an
inferior machine, that the measure of damages was an amount
sufficient to cover the deficiency, and that the contract price
was not conclusive as to the value of the machine’
_ 521. Remedy of the Guarantor Against His Principal. Where
a guarantor has been compelled to pay money for his principal
he can recover it back from the principal with legal interest.
And in case he has been sued by the guarantee and notified
his principal of that fact, and he refused to make a defense, if
the guarantor afterwards, in good faith, makes a defense in a
suit against his principal he can recover not only the money
paid out by him, but all reasonable and necessary expenses in-
curred in such defense, including counsel fees.’
6 Smith v. Rodgers, 14 Ind. 224; Benjamin v. Hilliard, supra.; Mana-
han v. Smith, 19 Ohio st. 384.
* Benjamin v. Hilliard, 23 How. U. S. 149.
One who has guaranteed that the drawee of an order will pay it with-
in aspecified time, is not entitled to notice of non-payment, and is hable
for interest from the expiration of the specified time. Gammel v. Para-
more, 58 Ga. 54; Davis Sewing Machine Co. v. McGinnis, 45 Iowa 538;
Pratt v. Procket, 20 Kans. 201.
' Westfield v. Mayo, 122 Mass. 100-109.
CHAPTER XXXII.
PERSONAL PROPERTY.
Warranty DEFINED. QUESTION DiscusseD. CAVEAT EMp-
ToR. Goopds SOLD BY SAMPLE. DAMAGES. EXCEPTIONS TO
THE GENERAL RULE. BR#ACH OF WARRANTY OF TITLE.
DAMAGES IN CASE OF DISEASED ANIMALS.
522. Warranty in Sale of Property. There are two kinds of
warranties, expressed and implied. Expressed warranty: In
the sale of personal property, no particular form of words is
necessary to constitute a warranty, although the word war-
ranty is generally used. Any assertion by the seller in respect
to the quality of the property, if intended by the seller and
understood by the buyer as such, will be taken as a warranty,
whether the word warranty is used in making the contract or
not.)
1 Jones v. Quick, 28 Ind. 125; House v. Fort, 4 Blackford 293; Sweet v.
Colgate, 20 Johns 196; Duffy v. Mason, 8 Cowen 25; Osgood v. Lewis, 2
Harr & Gill 495. :
450 LAW OF DAMAGES.
523. Where the seller is aware that the buyer is purchas-
ing property for a certain purpose he warrants it to be fit for
that purpose.’
524. The Question Discussed. The question frequently arises
in courts as to what shall be considered a warranty. It is now
pretty generally settled by the authorities that a mere silence
implies no warranty; neither do remarks which should be con-
strued a simple praise or commendation. Thus, wherein the
purchase of a horse the plaintiff made inquiries of the defen-
dant about his eyes the defendant responded that his eyes
were as “good as any horse’s eyes in the world,” the court held
there was no warranty.’ If the manufacturer of an article sells
it at a fair market price, knowing the purchaser designs to
apply it to a particular use or purpose, he impliedly warrants
it to be fit for that purpose, and, if owing to some defect in the
article not visible to the purchaser, it is unfit for the purpose
for which it is sold and bought, the seller is liable on his im-
plied warranty.
525. The Diligence the Law Requires the Purchaser to Exercise.
The law requires an individual to exercise his common sense
? Mann vy. Everston, 32 Ind. 355; Passinger v. Thornburn, 34 N. Y. 634;
Smeed v. Flood, 102 Eng. com. law, 612; Hadly v. Baxendale, 9 Exch.
341; Griffin v. Colver, 16 N. Y. 489; Jones v. Bright, 5 Bing. 533; Brown
v. Edgerton, 2 Mann & Gran 279; Randall v Roper, 96 Eng com. law, 82;
Field on the law of damages, sec 278, and notes.
* House v. Fort, 4 Black (Ind.) 293; Duffy v. Mason, 8 Cowen 25; Mor-
rill y. Wallace, 9 N. H 111; 1 Parson on contracts, p. 879.
* Brenton v. Davis, 8 Black (Ind.) 317; Jones v. Bright, 5 Bing. 533;
Gray v. Cox, 4 B. & C. 108; Lang v. Fisher, 6 Tount 108; Page v. Ford et
al., 12 Ind. 46; see on questions of discount in this chapter the following
authorities that bear on the subjects; Croke v. Lewis, 3 Sum 1; Bradford
v. Bush, 10 Ala. 386; Tishune v. Dever, 36 Ga. 618; McFalon v. Newman,
9 Watts 55; Kenly v. Fitzpatrick, 5 Miss 59; Morrill v. Wallace, 9 N. H.
111; Brown v. Stephens, 4 Ired (N. ©.) L. 411; Foggart v. Blackweller, 4
ib. 238; O’Neal v. Bacon, 1 Oust. 215; Hawkins v. Berry, 10 Ill. 36; Eden
v. Scott, 11 Ill. 35; Marsh v. Weber, 13 Minn. 109.
PERSONAL PROPERTY. 451
and judgment in making contracts, and if he fails to do so he
cannot recover for any loss that he might by the exercise of
such powers have prevented. Therefore, if the defendant war-
rants a horse to be sound and free from blemishes and it turns
out that he had no tail or but one ear, and such defect was
plain and obvious to the plaintiff at the time he made the pur-
chase, the law will presume that the parties did not under-
stand such defect as coming within the warranty. But if the
horse had other defects that were not plain and obvious to men
not skilled in the disease of such animals, the defendant can-
not claim that the defects were too plain and obvious to be
covered by the warranty.
526. Implied Warranty. It is a rule of law that is recog-
nized in most, if not all, of the States that the seller of per-
sonal property, which he has at the time in his possession,
warrants by implication that it is his own and that he has a
good title to the same, and this warranty arises from the fact
that possession in law is considered equivalent to an affirma-
tion of title. And this implied warranty not only means that
the vendor has a right to sell, but that it is free from incum-
brance. The essence of the contract is that the vendor has a
perfect title to the property sold, and that the purchaser will
acquire by the sale a title free and clear from prior liens and
incumbrance, and shall enjoy the possession without disturb-
ance by reason of anything that has been done or suffered to
be done by the vendor. And this implied warranty or affirm-
ation renders the vendor responsible if the title proves defective
inany way. And this responsibility the defendant incurs,
818 H. 4;1B. Pl. 4; South v. Howard, 2 Roll 5; Long v. Hicks, 2
Hump. 305; Diller v. Moore, 2 Eng. 166; Bordry v. Foster, 24 Barber 367;
Richardson v. Johnson, 1 La. An. 389; Howard v. Foster, 4 Blackford
294; Margerton v. Wright, 8 Bing. 454; 7 Bing. 603; Gatting v. Newell, 9
Ind. 572.
452 LAW OF DAMAGES.
although he may have made the trade in good faith.* If after
such sale the vendor acquires a good title free from incum-
brance, it will inure to the benefit of the vendor. But where .
the property sold is not at the time in possession of the vendor
there is no affirmation of title, and consequently no warranty,
and if it turns out that he had no title at the time of the sale,
unless he has defrauded the plaintiff, he will not be responsi-
ble for the failure of title. But a warranty of quality and
quantity, etc., will not be implied. It must be made in ex-
pressed terms, or in such a manner as to be understood between
the parties.°
527. Caveat Emptor, The rule is caveat emptor—let the
purchaser take care of his own interest. It is always in the
power of the vendee to obtain a warranty, and if he makes a
purchase without such a warranty the law will raise none in
his favor, and if his title fails he is without a remedy.'
528. The Time the Warranty Must be Made. The warranty
must be a part of the contract and made at the time the con-
tract is made. A warranty made after the delivery of the
* Defrees v. Trumper, 1 Johns 274; Hermancé v. Venoy, 6 Johns 5
Hubbard v. Johnson, 19 Johns 77; Sweet v. Colgate, 20 Johns 196; Reid
v. Barber, 3 Cowen 272; Coolige v. Bigham, 1 Met. 551; Buckingham v.
Goddard, 21 Pickering 70; Hale v. Smith, 6 Greenl. 420; Butler v. Tufts,
13 Met. 302; Thompson v. Dowell, 32 Me. 87; Huntington v. Hall, 36 Me.
501; Robins v. Rice, 20 Mo. 229; Eddie v Crim, 10 Bar. 445.
5 Sherman v. Chaplain Trans. Co., 31 Vt. 162; Wood v. Carvin, 1 How.
66.
But where the seller is not in possession of the property at the time of
the sale there is no implied warranty of title. 17 Ind. 365.
5 Mixer v. Coburn, 11 Met. 559; Wernor v. Lombard, 18 Pick. 59; Park-
enor v. Lee, 2 East 321; Stuart v. Wilkins, Dougl. 20; Johnson v. Coke, 3
Har. & J. 89; Holden v. Daikin, 4 Johns 421; Dean v. Mason, 4 Conn.
428; West v. Cunningham, 9 Port (Ala.) 104; Moses v. Meade, 1 Denio
378; McKinney v. Fort, 10 Tex. 220.
6 Norton et al. v. Hooten et al., 17 Ind. 365.
PERSONAL PROPERTY. 453
Acapedys and the passing of title would be without considera-
tion and void. If the vendor during the negotiation makes a
statement in regard to the quality of the property, or proposes
to sell it with warranty and the sale is not consummated at
that time, but at another and different time the vendee noti-
fies the vendor that he will take the property and the vendor
turns the property over to him, the warranty made at the first
interview will enter into and form a part of the contract of pur-
chase.? But if the vendor on the first interview propose to
warrant the property, but on a subsequent day completes the
sale and reduces the contract to writing, and the writing con-
tains no warranty, the law raises a conclusive presumption
that the whole of the agreement was reduced to writing and
.will not permit evidence to show the contrary, and the war-
ranty will be inoperative.’
529. Goods Sold by Sample. Where goods are sold by sam-
ple there is an implied warranty by the seller that the
bulk of the commodity or the goods sold shall be equal in kind
and quality to the sample exhibited to the buyer, and if when
the goods are received by the buyer they do not correspond
with the sample, the purchaser may refuse to receive them, or
if he receives them and afterwards on examination he finds
that they are not of the quality he purchased, he may ina
reasonable time return the goods to the seller and rescind the
contract, or he may keep the goods and sue the seller for
damages on his implied warranty.°
2 Kandall v. Rhoads, 1 Curt. 90.
* McCluer v. Jeffrey, 8 Ind. 79.
® Ransdell v. United States, 2 Ct of Col. 508; Hall v. Plassan, 19 La,
Am. 11; Beebe v. Robert, 12 Mass. 413; Boorman v. Jenks, 12 Mass. 566;
Rostly v. Thomas, 22 Texas 270; Andrews v. Kneeland, 6 Conn. 354;
Oneida Man. Co. v. Lawrence, 4 N. Y. 440; Bradford v. Manly, 13 Mass.
139; Williams v. Conger, 1 Peter C. Ct. 301; Magee v. Lingsly, 3 Ala. 679;
Waring v. Mason, 18 Wend. 425; Bower v. Lewis, 19 Barber 574; Whit-
454 LAW OF DAMAGES.
530. Damages in Case of Breach of Warranty. Where there
has been a breach of warranty and the plaintiff sues for dam-
ages, as a general rule he can recover the differences between the actual
value of the property at the date of the purchase and its value at that
date, if it had answered the terms of the warramty.”
And if the property is put up at a fair market value and
sold to the best advantage within a reasonable time after the
sale, the price realized will be prima facie evidence of the value
of the property at the time of the plaintiffs purchase.’
aker v. - Puedien: 29 Texas 355; Maute v. Gross, 56 Pa. st. 250;, Merrimon
v. Chapman, 32 Conn. 146; Dickerson v. Gay, 7 Allen 29; Gallagher v.
Waring, 9 Wend. 20; Salisbury v. Stainer, 19 Wend. 159; Muller v. Eno,
3 Duer (N. Y.) 421; Fraley v. Bispham, 10 Pa. st. 320; Moulton v. Parker,
1 Gray 123; Sanders v. Taylor, 5 Johns 395; Hargrave v. Stone, 5 N. Y. 73;
Warring v. Mason, 18 Wed., 425.
2Overbag, adm, v. Light, 27 Ind. 27; Durst v. Burton, 47 N. Y. 167;
Rawly v. Woodruff, 2 Lans. 419; Wells v. Selwood, 61 Barber (N. Y.) 238;
Edwards v. Colson, 5 Lans. 324; Merrimac Man. Co. v. Quintor, 107
Mass. 127; Frink v. Tatman, 36 Ind. 259; Lacy v. Stranghan, 11 Ia. 258;
Lukes v. Barr, 8 Ia. 368; Street v Chapman, 29 Ind. 142; Connor v.
Dempsy, 49 N. Y. 665; Tuttle v. Brown, 98 Mass. 205; Foster v. Rogers,
27 Ala. 602; Sharon v. Morsher, 17 Barber 518; Carr v. Moore, 41 N. H.
131; Page v. Parker, 40 N. H. 47; Fisk v. Hicks, 31 N. H. 588; Clare v.
Maynard, 7 Carr & P. 741; McAlpin v. Lee, 12 Conn. 129; Dengle v.
Hare, 7 C B. N.S. 145; Clare v. Maynard, 6 Ad. & El. 519; Burton v.
Young, 5 Harr 233; Hook v Stowell, 26 Ga. 704; Crabtree v Kile, 21 Ill.
180; Street v. Chapman, 29 Ill. 142; Molton v. Santon, 39 Me. 287; Grose
v Henry, 13 Allen 389; Fates v. McKeon 2 Hilt N. Y. 53; Renand v.
Peck, ib. 187; Muller v. Eno, 4 N. Y. 597; McGawe v. Wood, 1 Sneed,
181; Standenmire v. Williamson,29 Ala 558; Ferguson v. Harris,57 Ind. 438.
In an action for a breach of warranty in the soundness of a horse,
which the plaintiff obtained in exchange for another horse, the measure
of damages is the difference between the value of the horse in his un-
sound condition and bis value if sound. Wallace v. Wren, 32 Ill. 75.
5 Overbag v. Light, 27 Ind. 27.
The rule of damages in an action for breach of warranty is the differ-
ence between the actual value of the property at the time of the sale and
what its value would have been had it been as warranted to be, but
where there is no evidence as to the value of the property as warranted,
except what may be inferred from the price stipulated in the sale, that
price may be taken as what its value would have been had it been as
warranted. Houghton v. Carpenter, 40 Vt. 588,
PERSONAL PROPERTY. 455
And the price paid by the plaintiff will also be prima facie
evidence of the value of such an article as would have fulfilled
the terms of the warranty.‘
531. The Exceptions to the General Rule. To the general rule
we have laid down there are several exceptions in which con-
sequented damages are allowed. Thus in the case of Walcott
vs. Mount the plaintiff brought suit for damages for a breach
of warranty in the purchase of turnip seed. The plaintiff
purchased of the defendant what was represented to be “ early
strap-leaf red-top turnip seed.” The defendant was a dealer in
seeds and the plaintiff was a farmer. The plaintiff went into
the defendant’s store and informed him that he wanted to pur-
chase a quantity of such seeds in order to raise a crop for the
early market. The defendant showed him the seed and told
him it was the kind he inquired for and sold it tohim. The
inspection and examination of the seed were of no service to
the plaintiff. The seed were of an inferior quality. The
plaintiff sowed the seed and cultivated the ground and raised
an inferior crop of turnips. The court, in commenting upon
the question of damages, says: “In the much canvassed case
of Hadly vs. Baxendale, 9 Exch. 341, Alderson B. in pronounc-
ing the judgment of the court enunciated certain principles on
which damages should be awarded for a breach of contract
4 Overbag, adm., v. Light, 27 Ind, 27; Street v. Chapman, 29 Ind. 142.
The general rule in an action by the vendee for a breach of warranty
is the difference between the price paid and the worth of the article at
the time of delivery, with its defects and vice. But if the vendee has
sustained other additional injury, which is either the immediate conse-
quence of the failure of the vendor to perform his contract or a material
incident thereto, he may recover such damages. Witz v. Morrison, 17
Texas 372. 4
On gale of a horse with warranty it was held that the measure of dam-
ages in case of breach was the difference between the value of the ani-
mal answering the warranted character and its actual value at the sale.
Lacy v. Shanghan, 11 Iowa 258. :
456 LAW OF DAMAGES.
which assimilated damages in an action of contract to actions
in tort. The rule there adopted as resting in the foundation
of correct legal principles, was that the damages recoverable
for a breach of contract were either such as might be considered
as atising naturally 7. e., according to the usual course of things,
from the breach of the contract itself or such as might reason-
ably be supposed to have been in contemplation of both parties
at the time they. made the contract as the probable result of
the breach of it, and that when the contract was made under
special circumstances, if these circumstances are communi-
cated the amount of injury which would ordinarily follow from
the breach of the contract under such circumstances may be
recovered as damages that would reasonably be expected to re-
sult from such breach.” The court held that the sale of seed
‘by a dealer keeping them for sale for gardening purposes to a
purchaser engaged in that business would of itself imply
knowledge of the use which was intended sufficient to amount
to notice, and that the measure of damages was the difference
between the market value of the crop raised and the same crop
from the seed ordered.®
532. So where the plaintiff purchased of the defendant a
quantity of cabbage seed the defendant warranted the same to
be Bristol cabbage seed, and that such seed would produce
Bristol cabbage. It turned out that it was not such seed.
The plaintiff cultivated the seed and raised a crop of cabbage,
but not Bristol cabbage. Suit was brought by the plaintiff to
recover damage. The court held that the measure of damages
would be the value ofa crop of Bristol cabbage, such as the jury
should believe would ordinarily have been produced that year,
deducting all expenses of raising the crop and also deducting
the products or value of the crop actually raised.‘
56N Y. 262;34N. Y. 634.
* Passinger v. Troburn, 34 N. Y. 634; see Griffin v. Colver, 16 N. Y.
PERSONAL PROPERTY. 457
538. Randall vs. Roper. In this case the declaration
charged that the defendant by warranting thirty quarts of seed
barley sold the same to the plaintiff, and averred that the said
seed barley was chevalier seed barley; that the s&id plain-
tiff having purchased said seed barley for the purpose of resell-
ing, did, without having any notice or knowledge of said
breach of warranty, and believing said seed barley to be cheva-
lier seed barley, when, in fact, it was not chevalier seed barley,
and that the buyer had sowed the same without notice of the
fact in their respective lands as and for chevalier seed barley,
and the same not being chevalier seed barley yielded and pro-
duced rauch less and inferior crops and crops of an inferior
quality of barley than the same otherwise would have done had
the same been chevalier seed barley. It was agreed that the
difference in price between chevalier seed barley and the seed
barley delivered was £15, and that the loss to the parties who
had purchased of the plaintiff by reason of the difference in
their crops was in all £261 7s. 6d. These purchasers had made
claims upon the plaintiff for compensation, and the plaintiff
had agreed to satisfy them. A verdict was taken for £261 7s.
6d., with leave to the defendant to move to reduce it to £15.
The rule was refused. Compton, J., said: “Taking the nar-
rowest rule as to the probable and necessary consequence.of a
breach these damages fall within it, and all the Judges held
and agreed that the plaintiffs were entitled to recover the
damages sustained by their vendee upon a breach of warranty.”*
262; Jones v. Bright, 5 Bing. 533; Brown v. Edgerton, 2 Mann & Grau
279; Oliver v. Hanly, 5 Neb. 439; Fleck v. Weatherton, 20 Wis. 392; 39 N.
Y, 53; 3 N. J. 262; 69 N. Y. 62; Feris v. Comstock, 33 Conn. 513; White v.
Miller, 71 N. Y. 118.
In aguit on a warranty of onion seed, which proved worthless, it was
held that the plaintiff was entitled to recover as damages the amount
paid for the seed, the value of his labor in preparing his ground for the
seed. after deducting the benefits to the land, and the value of his labor
in planting the seed, with interest on the several amounts. 33-Conn. 513.
* 96 Eng. com. law, 82.
458 LAW OF DAMAGES.
534. And it is a well settled rule of law in this country
that where an article is sold with a warranty and the vendee
resells with a like warranty, the sum paid by him in an action
by his swbvendee for a breach of that warranty is prima facie
evidence of the amount which he will be entitled to recover
from his vendor in an,action in his own behalf.’
535. Breach of Warranty of Title. In an action upon a war-
ranty of title to personal property, the measure of damages is
the price paid with interest thereon, together with the costs
recovered by the true owner against the purchaser in a suit to
recover the property or its value, but costs can only be recov-
ered when the vendor had due notice of the pendancy of the
action.» The authorities are somewhat in conflict as to what
expense the vendee may lawfully make in defending his title
that he can recover from the vendor. But it may now be con-
sidered pretty well settled that he may make any defense in
good faith that he may see proper, and if he is defeated in the
suit he may recover from the vendor the price of the property,
with interest and costs.®
536. Where an action was brought on a guaranty that
stock sold should be worth seven hundred dollars within a year
from the date of the contract, it was held on breach that the
® Reggio v. Bragiotti, 7 Cush. 166; Armstrong v. Perry, 5 Wend. 535;
Blasdale v. Babcock, 1 Johns 518; Muller v. Eno, 4 Kern 597; Foster v.
Rogers, 27 Ala. 602; Field on law of dam., sec. 274.
§ Armstrong v. Perey, 5 Wend. 535; Case v. Hall, 24 Wend. 102; Bent
v. Denny, 31 Barber 540; Shattuck v. Green, 104 Mass. 42; Rawland v.
Shelton, 25 Ala. 217.
In New York the vendee was sued in trover for a horse he had pur-
chased with warranty. Judgment against him for the value of the
horse. He then sued his vendor for the price of the horse. Held, that
he could recover the amount recovered in the trover suit and the costs.
Blasdale v. Babcock, 1 Johnson 517; see Cooleridge v, Bingham, 1 Met.
547.
PERSONAL PROPERTY. 459
measure of damages was the difference between the highest
market value reached by the stock within the specified time
and seven hundred dollars.*
537. Diseased Animals. The defendant sold to the plaintiff
two oxen. At the time the plaintiff made the purchase he
told the defendant that he would not have them if there was
the least fear of disease, as he desired to put them with his
other stock, whereupon the defendant replied that they were
quite sound and free from disease. The plaintiff took them
home and placed them with other cattle. The two oxen died
of the rinderpest, which they had upon them at the time of
the sale. They communicated the disease to other cattle, nine
of which died from such disease. Plaintiff brought suit on his
warranty. The court held that the plaintiff could recover not
only for the two oxen purchased, but for that of the nine other
beasts which had caught the disease and died.”
538. In a recent case one who sold a cow toa farmer with-
out fraud, warranted her-free from foot and mouth disease.
The cow had disease and communicated it to other cows be-
® Woodward v. Powers, 105 Mass. 108.
7 Knowles v. Nunn, 14 L. J. N. S. 592.
In an action of fraud in the sale of diseased sheep where there was a
warranty of soundness, it was held that the purchaser could either re-
scind the contract and on return of the property recover back the price
paid or retain the same and recover damages, and that these damages
should not only embrace the difference between the value of sound
sheep and the sheep received, but also the loss resulting from the com-
munication of the disease to other sheep of the plaintiff with which,
without the fault of the plaintiff, they were mingled. Marsh v. Weber,
16 Minn. 418; Jefferson v. Biglow, 13 Wend. 518.
In Texas if the vendee sustains additional injury, which is the imme-
diate consequence of the breach of warranty or a material incident there-
to, he may recover the damages in addition to the difference in value.
Wentz v. Morrison, 17 Texas 372; Randall v. Roper, 1 E. B. & E. 84;
4 Jur. N.S. 547; 35 L. J. C. P. 399; 14 W. R. 898; 14 L. J. N. S. 558; Rose
v. Wallace, 11 Ind. 112; Faris v. Lewis, 2 B. Mon. 375.
460 LAW OF DAMAGES.
longing to the plaintiff, with which she had, in the ordinary
course of his business, been placed, and she and several of them
died in consequence. The presiding Judge charged the jury
that in estimating the plaintiff's damages they might consider
the fact that the plaintiff was a farmer and that the seller
knew or must be taken to know that the cow in question
would be placed with other cows, and that the consequence
which resulted might naturally have been expected. The
plaintiff had judgement for the loss of all the cows.’
539. And it may now be laid down as a general rule that
the plaintiff in an action for a breach of warranty can recover
such damages as may fairly and reasonably be considered either
arising naturally, that is according to the usual course of
things, from such breach or such as may reasonably be sup-
posed to have been in contemplation of both parties at the time
they made the contract as the probable result of the breach of
it. It has, therefore, been frequently held that in a suit for a
breach of warranty for the soundness of an animal, that the
plaintiff could not only recover damages for the difference be-
tween the actual value of the animal at the time of the pur-
chase and its value at the same time, if it had answered the
terms of the warranty, but also reasonable expense incurred in
taking care of and trying to cure the animal, together with the
expense of keeping it for such a reasonable length of time as
was necessary to effect a sale at the best advantage, including
expense of selling.?
‘540. In the case of Page v. Ford, the plaintiff by cross-
1 Smith v. Green, L. R. 1 C. P. D. 92.
The same rule applies in case of fraud. Mullett v. Mason, L. R. I. C.
559.
* Perry v. Andrews, 41 Vt. 631; Clare v. Maynard, 7 C. & P. 741; Ellis
v. Chinnack, 7 C. & P. 169; Chesterman v. Lamb, 4 Nev. & M. 195; Sedg.
on dam., 289; Fagin v. Beasly, 23 Go. 17.
PERSONAL PROPERTY. 461
bill alleged that he had purchased of the defendant a steam
engine and boiler which the defendant had manufactured for
him, to be used in a saw-mill of the plaintiff's, of which the
defendant had knowledge and made them expressly for that
purpose ; that the boiler was worthless in consequence of defect
in material and workmanship; that soon after it was set up,
owing wholly to such defect, it bursted, and by reagon of it
bursting the plaintiff’s mill was injured, etc. The court held
that if the engine proved unsound and unfit for the purposes
to which it was to be applied, and if in attempting to apply it
as proposed the purchaser should, without fault upon his part,
in consequence of such unsoundness and unfitness suffer dam-
agos by the destruction of that kind of property, which it was
reasonable the parties to the contract contemplated would be
necessarily placed in close proximity to the machinery, that
the plaintiff could recover damage for such destruction.’
541. It isa settled rule of law that where manufacturers
undertake to construct.and set up within a specified time an
engine or other machinery of a stipulated quality or power,
and he fails to deliver the article within the time specified
and of the quality designated, the measure of damages is the
difference between the machinery furnished and that called
for by the contract, to which may be added the damages result-
ing from a failure to deliver within the time.’ Profits that
the plaintiff would certainly have realized, but for the defen-
dant’s default, can be recovered. Those which are speculative
cannot.®
. 142 Ind. 46; see also Long v. Langridge, 2M. & W.519; 4 ib. 337; Pal-
mer v. Pierce, 2 Sand. (S. C.) 120; White v. Mapily,.8 Pickering, 356;
Driggs v. Dwight, 17 Wend. 71-74; Brown v, Edgerton, 2 M. & G, 433; 2
Cush. 46; Lawrence v. Wardwell, 6 Barber 250; McAfee v. Crawford, 13
How. 447.
2 Griffin v. Colver, 16 N Y. 489; Fisk v. Tank, 12 Wis. 276.
8 Griffin vy. Colver, supra; West Gravel Road Co. v. Cox, 39 Ind. 260;
462 LAW OF DAMAGES.
542. The rule in England is clearly laid down in the case
of Smeed v. Ford, where the plaintiff purchased from the de-
fendant a steam thrashing machine to be delivered in three
weeks from the time of the purchase, or from the 24th of July.
The plaintiff desired to use the machine to thrash out his
wheat in the field and at once send it to market. The defen-
dant failed to deliver the machine. The plaintiff’s wheat was
greatly damaged by reason of a heavy rain-fall, so that it was
almost worthless. Suit was brought for damages. Lord
Campbell, in commenting upon the case, said: “The ques-
tion is whether under the circumstances surrounding the case
the plaintiff can only recover nominal damages or whether he
is entitled to substantial damages. The rule is to be taken
from Hadly vs. Baxendale, which accords with the code Napo-
leon, with Pothier, and with Chancelor Kent, and which de-
cides that the plaintiff is entitled to receive as a compensation
such damages as are the natural consequence of the breach of
the contract, or such as may reasonably be supposed to have
been in the contemplation of the parties. I do not say how
far this rule applies to the circumstances of that case, but it is
an obstructory rule of law which I agree with. Then apply-
ing that rule to this case, I say that the plaintiff is entitled to
substantial damages, for this is not like the case of a horse in-
tended to run a race, which was sent by a railway and was not
delivered in time, so that he lost the chance of winning the
race, nor like the case of fight which might have won the
pize, nor like the other cases put by Lord Ellensborough of a
man traveling who was delayed on his journey by the coach
breaking down per quoad, and who lost his lieutenantcy. The
plaintiff, who was a large farmer, was known by the defandant
to be accustomed to thrash out his wheat in the field. He
3 Wheat 546; 5 Wheat 385; Rhoads v. Baird, 16 Ohio st. 573; Davis v.
Cin. R. R Co, 1 Denny 23; Cooper v. Young, 22 Ga. 269; Taylor v, Ma-
guire, 12 Mo. 313; 13 Mo. 517; Singer v. Farnsworth, 2 Ind. 597.
PERSONAL PROPERTY. 463
gave the order for the thrashing machine, which was agreed
should be delivered on the 14th of August, at which time the
wheat might reasonably be expected to be ripe for thrashing.
The defendant knew that it was wanted for that purpose. Then
was it not on the contemplation of the parties that if it was
not delivered at that time damages by rain might ensue to the
plaintiff? The thunder storm occurred and the plaintiff's
wheat was damaged. If the engine had been delivered at the
time agreed upon the wheat would have been thrashed out
and would havé been carried to market in good condition, in-
stead of which it was damaged. Is not the injury a natural
consequence of the breach of the contract, and may it not rea-
sonably be supposed to have been foreseen’ by the parties?”
There was no want of diligence on the part of the plaintiff to
procure another machine. The court held that the plaintiff
was entitled to recover damages for the injury to his wheat
caused by the rain. But that he could not recover for the fall
in the market price, as that could not have been in contempla-
tion by the parties at the time they made the contract.‘
543. The American Rule. As we have already intimated,
the party “injured is entitled to recover all his damages, in-
cluding gains prevented as well as losses sustained, and this
rule is subject to but two conditions. The damages must be
such as may fairly be supposed to have entered into the con-
templation of the parties when they made the contract, that is
they must be such as might naturally be expected to follow its
* Smeed v. Ford, 28 L. J. Q. B. N. S. 178; Sedgwick’s leading cases on
damage, 275. 3
In an action for a false warranty in the sale of chattels, the measure of
damages is the injury sustained by the plaintiff in consequence of the
breach. Hogan v. Thornin: ton, 8 Post Ala. 428.
The same transaction cannot be characterized as a warranty and a
fraud at the same time. A warranty rest on contract. Fraud and fraud-
ulent representations have no elements of contract in them. 49 Ind. 77.
464 LAW OF DAMAGES.
violation, and they must be certain both in their nature and
in respect to the cause from which they proceed.”
544, Goods Bought for a Certain Market. And it may be
laid down as a general rule that where goods are bought for a
certain market and the seller is apprised of that fact, he war-
rants them to be fit for such market; in an action for a breach
of the warranty, the plaintiff will be entitled to damages for
all losses sustained, including the profits he would have ‘made
upon the sale, had the articles been as represented.
544. The Price Paid. There has been and now is some
confusion in the books as to the measure of damages in an ac-
tion fora breach of warranty of the quality of property pur-
chased. It is contended by a few authorities that in no case
can the plaintiff recoveran amount in excess of the purchase
5 Griffith v. Colver, 16 N. J. 469; Hamilton v. McPherson, 28 N. Y. 72;
Krom v. Long, 48 NY. 679; Crater v. Berger. 33 N. Y 513; Delvin v.
Mayor, 683 N. Y 8; Pittsburg Coal Co. v. Foster, 8 Am. Law Regs. 368;
Fasseler v. Love, 12 Wright 410-411; Fleming v. Beck, 12 Wright 312-313.
Where damages were claimed for a breach of warranty in the sale of
machinery by a person not a manufacturer and where no fraud was
charged, it was held to be an error to instruct the jury that they might
allow as damages the value of the use of the machine for a reasonable
time to make the repairs necessary to cause the machinery to comply
with the warranty Booker v. Goldsborough. 44 Ind 490.
6 Lewis v. Rountree, 79 N. C., 122. ‘
A similar relaxation of this restrictive rule has been made, at least to
a qualified extent in action on contract and loss of profits, resulting nat-
urally from the breach of the contract hasbeen allowed to enter into the
damages recoverable, where the profits that might have been realized
from the performance of the contract are capable of being estimated
with a reasonable degree of certainty. In an action on a warranty of
goods adapted to the China market, and purchased with a view to that
trade, the purchaser was allowed damages with reference to their value
in China as representing the benefits he would have received from the
contract if the defendant had performed it. Bridge v. Wain, 1 Starke,
504. See Smith v. McGuire, 3 H. & N., 554; Hadley v. Baxendale, 9
Exch., 341.
PERSONAL PROPERTY. 465
XN
price. And that the true measure of damages is the difference
between the purchase price and the actual value of the prop-
erty with the defect.’ But this rule has been gradually de-
clining until it is now, as has already been said, only recognized
by the courts of a few States. The Supreme Court of the
State of Iowa in a recent case which was brought by the plain-
tiff to recover damages for a breach of warranty in the sale
of bonds of the city of Memphis, Tennessee, with semi-annu-
al interest coupons attached thereto, the complaint alleged
“that the defendant agreed that the principal of the bonds
was or should be guaranteed and provided for by the sinking
fund set aside for that purpose.” And further “that said in-
terest coupons as delivered to the plaintif were not paid at
maturity, and that neither the defendant nor the city of Mem-
phis aforesaid have provided for the payment of the principal
of said bonds, and that neither the defendant nor the city of
Memphis have set aside any sinking or any other fund for the
payment therefrom of the intercst on said bonds, or were the
ultimate payment of the principal of such bonds should be
paid.” The court, after holding that the agreement eonstitu-
ted a warranty, said: “The plaintiff claims as damages the
difference between the market value of the bonds such as were
in fact delivered, and the market value of the bonds secured by a
special fund for their payment, in accordance with the defend-
ant’s warranty. He says the bonds would, in the market, have
been worth one hundred cents on the nominal dollar, therefore,
if the defendat had kept their agreement good, and the bonds
actually delivered are worth only half that sum in the market,.
and he asks for judgment for the differenee with interest. -
While there has been great fluctuation of judicial opinion on
the question of the measure of damages in cases of a breach of
warranty in the sale of personal property, Mr. Sedgwick states
the result of the cases that “the true measureof damages is the
7 Caswell v. Coare, 1 Tount, 566, Mayne on dam., 88.
466 LAW OF DAMAGES.
difference between the value of the thing sold would have had
at the time of the sale if it had been sound, or corresponded
with the warranty, and its actual value with the defect? * *
(citing many authorities given at bottom of this page). Ther®
are many other cases holding to the same rule, while some of
the early cases hold the measure of damages to be the differ-
ence between the price paid, or to be paid, and the real value.
The rule as stated by Mr. Sedgwick and contended for by the
plaintiff has beens adopted by this court * * ‘(case cited
_ below), in which case the defendant. pointed out and pretended
to sell the plaintiff one tract of land, and fraudulently con-
veyed to him another, and it was held that the measure of
damages was the difference between the two pieces of land®
545. As far as we have been able to ascertain the only
States in which the old rule, making the measure of damages
the difference between the price paid and the value of the
property with the defects, are Illinois,’ Connecticut,® and
Georgia.’
546. Damages in Case of a Failure to Deliver Personal Property.
The authorities are not uniform in this country upon the sub-
ject of the measure of damages in an action on a breach of
contract for the delivery of personal property. They all agree,
however, that the vendee should have full compensation for
Sedgwick on the measure of dam. 324; VanAllen v. Il]. Cent. R. Co.,
7 Bows 515; Simpkins v. Low, 49 Barb. 382; Cary v. Guman, 4 Hill 625;
Comstock v. Hutchin, 10 Barb. 211; Thornton v. Thompson, 4 Gott 121;
Woodward v Hocker, 21 Vt. 580; Staughter v. McRoe, 3 La. Ann 455;
Borrikins v. Beauens, 3 Ramh 23; Roberts v. Carter, 28 Barb 462.
2Hahn v. Cummings, 3 Iowa 583.
sCallaman v. Brown & Co, 18 Ia. 333.
sMorgan v. Ryeson, 20 Ill. 343; Crabtree v. Kile, 21 Il. 180.
*McAlpin v. Lee, 12 Conn. 12; Ferris v. Comstock, 33 id 513.
iClark v. Neefnill, 46 Georg. 261. \
PERSONAL PROPERTY. 467
actual loss sustained. They only differ in regard to the rule
courts and juries should adopt in assessing the plaintiff actual
loss, or in awarding him full compensation; but we think that
the principle generally recognized by the courts of the differ-
ent States for the assessment of damages on a breach of an
executor contract to deliver personal property sold in the
absence of fraud is as follows:' Where the price has not been
paid, the actual loss sustained is the difference’ between the
contract price and market value of the property at the time and
place the delivery should have beenmade.’ This rule is adopt-
ed in almost all commercial transactions, and where the prop-
erty has been advanced in value between the time of the sale
and delivery.
The reason for this rule is that the vendee who has been
deprived of the benefit of his bargain if he had received the
property could not have realized more from its sale than such
property was worth in the market ; or if property of the same
kind and quality could have been procured at the same place
it was his duty to have at once invested his money in the pur-
chase of such property as he had contracted for. Therefore his
actual loss would only be the rise in the value of the property
between -the time of the sale and the time fixed for the
delivery.
\
2 Dana v. Fiedler, 12 N. Y. 220; Field on law of dam. 232; McKnight
v. Dunlope, 1 Seld. N.Y 537; Billings v. Vanderbeck, 23 Barb 546; Zen-
her v. Dale, 25 Ind. 433; White v. Tompkins, 52 Pa. St 363; 3 Parsons
on Contoact 205; Pillpotts v. Evans, 5 M. & W. 475; Rand v. The White
Mountain River Company, 40 N. H. 79; Cannon v, Folsom. 2 Ia. 101;
Crosley v Walkins, 12 Col. 12 Col. 85; Bartlett v. Blanchard, 18 Gray
429; Barnard v. Conyer. 6 McClane C. ©. 497, 6 Wheat 109-118; 2 Wend.
899-407, 3 Cow. 82; Davis v. Shield, 24 Wis. 322; Arnold v. Suffolk Bank,
27 Barb. 424; Clark v. Penn, 7 Cow 681; Davenport v. Wells, 1 Ia. 598°
Canan v. Folsom, 2 Ia. 101; Ronden v. Eaton, 4 Tex. 289; Collen v. Me
Fadden, 18 Texas 324; Stewart v. Price, 3 Texas 715. ®
468 LAW OF DAMAGES.
His complete indemnity is to receive that sum which,
with the price he agreed to pay, would enable ‘him to buy the:
article which the vendor had failed to deliver, or an amount
that would place the vendee or plaintiff in the same financial
condition that "he would have been had the property been
delivered pursuant to contract.’ ;
547. When the Price Has Been Paid. In several of th>
States a different rule prevails, and in case where the purchase
money has been paid in advance, the measure of damages on
breach of contract for the delivery of personal property is the
highest market value at any time between the breach and the
commencement of the suit, and even in some States to the
time of the trial, provided the plaintiff acts with promptness
in bringing his action.‘ The reason for this rule is this, that
the party to whom compensation is due must be fully indem-
nified and that the wrong doer must not be permitted to de-
rive any benefit or advantage from his wrongful act, and that
this indemnity will be arrived at by adding to the value of the
property at the date of the breach the damages that the ven-
dee has proven to have sustained, every- increase of value that
5 Dana v. Field, 12 N. Y. 40.
If the party entitled to the benefit of a contract can protect from loss
arising from the breach thereof at a trifling expense, or with reasonable
exertion, it is his duty to do it. And he can charge the delinquent
party with such kamages only as with reasonable endeavor and expense
he could not prevent. Muller v. Marine Church, 7 Greenl. 51.
In a suit instituted with reasonable diligence on a breach of contract
for the sale and delivery of new corn, which had been paid for in ad-
vance, the measure of damages is the highest market price of corn at
any time between the contract time of the delivery and the rendition of
the verdict. Kent v. Ginter, 21 Ind 1; see Clark v. Penney, 7 Com.
N. Y. 681; West v. Wentworth, 3Conn 82, 2 Conn. 488; Davis v. Shields,
24 Wend. 322; Arnold v. Suffolk Bank, 27 Barb. 424; 19 Conn. 212; 4
Texas 289; 13 Texas 212; 2 Iowa 201; 6 Georgia 520; 20 Ala. 694; 1 Nott.
& Cord. 334; Shepherd v. Hampton, 3 Wheaton 200.
Seedom dam. v. Jenks, 3 Sandford, 8. C. R., 618.
PERSONAL PROPERTY. 469
the wrong doer has obtained, or had in his’ power to obtain.,
And further, that the vendee or purchaser having parted with
his money may not be able to go into the market and purchase
other goods.6 But this rule has not, as we have already no-
ticed, been generally adopted. For the courts of quite a num-
ber of the States hold that the true measure of damages, even
where the purchase money has been paid in advance, is the
value of the property at the time and place of delivery, ‘or
whether the price is paid or not, the difference between the
contract price and the market value of the article at the stip-
ulated time and place of delivery when the price has advanced
together with the amount paid on the contract.”* And where
the price is not paid, or only partly paid, the same rule is gen-
erally and everywhere recognized,
548. McHose v. Fulmick. In this case the Supreme Court
of the State of Pennsylvania in commenting upon this ques-
tion says: “When a vendor fails to comply with his contract,
the general rule for the measure of damages undoubtedly is the
difference between the market price of the article at the time
of the breach. This is for the evident reason that the vendee
5Seedom v. Jenks, 3 Sanford S. C. R. 613; Sedgwick on dam. (3d ed.)
291; Millison v. Hoch, 17 Ind. 227.
® Kountz v. Kerkpatrick, 72 Pa. St. 22.
6 Fiold on the law of damages, sec. 246.
7™The difference between the contract price and the market value at
the time and place of delivery is the measure of damages, whether the
article was paid for or not.” Startup v. Corterri, 2 Crankyann M & R’s
Exch. Reps. 165; 3 Sanford S. C. 614; 16 Pick 194; 5 Watts & Seg. 106;
11 Serg. & R 452; 2 Kent (2d ed.) 480; Sedgwick on measure of dam-
ages 288-290; Lorder v. Allen, 2 Bibb, Ky. 388; Gottering v. Neuell, 12
Ind. 125; Houg v. Meyers, 9 Ind. 391; Beckel vy. Colton, 41 Miss. 368;
Haskell v. Hunter, 23 Mich. 305; Northrupt v. Cook, 39 Mo. 208; Ward
vy. Burr, 5 Block (Ind) 116; Baldwin v. Nichols, 4 E D S. (N. Y.) 14;
Hamilton v. Ganyard, 34 Barb. (N. Y.) 204; Carrie v. White, 37 Home
Pract. 330. York v. Verplank, 65 Barb. 316; Copper Co. v. Copper Min-
ing Co., 33 Vt. 62.
470 LAW OF DAMAGES.
can go into the market and obtain the article contracted for at
that price. But when the circumstances of the case are such
that the vendee cannot thus supply himself the rule does not
apply. * * * Ifan article of the same quality can
not be procured in the market its market price cannot be as-
certained, and we are without a necessary data for the applica-
tion of the general rule. Thisis a contingency which must be
considered to have been in the contemplation of the parties,
for they must be presumed to know whether such articles are
of limited production or not. Insuch a case the true measure
of damageg is the actual loss the vendee sustains,’
549. Damages where Property is sold for a Purpose. Where the
defendant sells an article that he knows the plaintiff intends
to use to fulfill a sub-contract and the defendant has knowledge
of its terms, the plaintiff may recover the difference between
thesub-contract price and the principal contract price, and this
is upon the ground that the parties have impliedly fixed the
measure of damages, or rather, made the contract upon the
basis of a fixed rule, by which they may be assessed. But the
question is not fully settled by the authorities whether this
rule can, under any circumstances be applied when the article
purchased has a market value. But applying the rule laid
down in the case of Hadley v. Baxendale, that if the special
circumstances under which the contract was actually made
were communicated to the plaintiff, and thus known to both
parties, the damages resulting from the breach of such con-
tract, which they would reasonably contemplate would be the
amount of injury which would ordinarily follow from the
breach of the contract. We are inclined to the opinion that
the rule would apply even where the article purchased had a
market value.’
™73 Pa. st., 865.
_* Booth v. the Spuyten Dunill Rolling Mill Co., 60 N. Y., 487; 114 C.
PERSONAL PROPERTY. 471
550. In the case of Booth v. The Suyten Dunnill Rolling
Mill Co., which was a suit for a breach of contract to furnish
the plaintiff with four hundred tons of steel-capped rails. The
defendant agreed to make and deliver them to the plaintiff
during the months of January, February and-March. The de-
fendant before making the agreement was informed of the plain.
tiff’s contract with the Central Railway Company, and that
the caps were necessary to be used in making the rails. Both
parties knew the caps could not be procured elsewhere in time
to enable the plaintiff to fulfill his agreement to: deliver the
caps to the Railway Company. The iron base and steel cap of
a rail, when separated, had no market value, nor was there any
market value for the complete rail. The defendant failed to
deliver the caps as per agreement. The Court held that the
plaintiff could recover the amount of profits he would have
made in the whole transaction. In other words his damages
was the profits he would have made on the sale of the caps to
the railroad company.?
551. Again. In the case of Borries v. Hutchinson, which
was an action brought for a breach of contract to deliver a
quantity of costic soda. The Court held that as the article
was not one of constant demand and supply, so that there was
no market which could be resorted to for the purpose of ob-
taining it; that the rule allowed the assessment of the plain-
tiff’s damages at the difference between the value of the goods
at the time of the breach of contract, as compared with the
contract price, did not apply, and that the basis of the plain-
tiff’s damages was not the market price of the. goods at the
L. R.. 445; 7L. RB. C. P., 587; 26 L. & Eq., 398; 34 N. Y., 364; 40 N. Y.,
422: 9C. L R, 82; 54N. Y., 586; 3 Q. B., 181; 102 E. C. L., 602; L. R. 3
C B., 449; L. R 8C. P.,131; Borries v. Hutchison, 18 C. B.; N S., 445;
8S. C,, 34; L. J. N. S.C. P. 169; 11 Jur. N.S., 267; 13 W. R 384; 11 L. T.
N.S., 77.
560 N. Y., 487.
472 LAW OF DAMAGES.
time of the breach. And that as the defendant had notice at
the time he sold the goods that the plaintiff desired them for
the purpose of resale to a sub-vendee,on the same continent,
that a differen’ rule for the assessment of damages must be re-
sorted to, and that the rule laid down in the case of Hadley
y. Baxendale was applicable where it was held that when two
parties have made a contract which one of them has broken,
the damages which the other party ought to receive in respect
to such breach of contract should be such as may fairly and
reasonably be considered as arising naturally, that is, according
to the usual course of things-from such breach of contract it-
self, or such as may reasonably be supposed to have been in
the contemplation of both parties at the time they made the
contract as.the probable result of the breacu of it. And that,
according to this rule the plaintiff could recover the difference
between his purchase price, and the price he had re-sold it for,
or, in other words the loss of profits on the re-sale.®
552. And in a recent case where the plaintiff purchased
a large amount of shirting, to be manufactured according to
samples and informed the defendant before the consumation of
the bargain that he was purchasing it for shipment, the de-
fendant agreed to furnish the required amount at a’fixed price,
and with an agreement to deliver at a designated time. The
defendant, before the time fixed for the delivery, notified the ‘
plaintiff that he could not comply with the contract. There
were no other goods of the kind in the market, and the plain-
tiff, to fulfill his contract with his sub-vendee, had to buy else-
where,-at a high price, goods which were better but were in
quality and price the nearest obtainable to those contracted
for. He was allowed to recover the difference between the
price he contracted to pay the defendant and that he was
forced to pay elsewhere.®
5 Borries v. Hutchinson, 18 C. B. N. S., 445; 8. C., 34.
“Hinde v. Liddle, L. R. 10 Q. B. 265.
PERSONAL PROPERTY. 473
553. Dai®ges where the Goods are to be Delivered at Different
Times. The courts have had great difficulty in arriving at the
measure of damages in cases where defendants have agreed to
deliver goods in certain quantities, at stipulated times, and
before the time appointed for the delivery of the last quantity
refuse to comply with the contract. It is contended by some
authors that the plaintiff can, on the refusal of the defendant
tocomply, consider the contract at an end and bring suit to
recover damages for a breach of the whole contract. But the
better rule is that in the absence of evidence on the part of the
defendant that the plaintiff could have obtained a new con-
tract on such terms as to mitigate his loss, the true measure of
damages is the sum of the differences between the contract
price and the market price at the several periods for delivery,
notwithstanding the fact that the last period ,had not elapsed
-when the plaintiff commenced his action.’
554. The Case of Hadly vs. Baxendale. The rule laid down
for the assessment of damages in this famous case about a
quarter of a century ago, by the English Exchequer court, has
been commented upon by courts and law writers in almost
every nation in the civilized world, and is everywhere recog-
nized for its sound logic and equitable principles. It seems
to have been the first case in which the question of limitation
of responsibility for a breach of contract was definitely and
satisfactorily settled. The rule there laid down isa simple
one; and perhaps is as free from objection as any that could be
established. It is based on the idea, or presumption, that par-
ties in making a contract take into consideration, the injurious
consequences that will naturally follow in the case of the
breach of it. Therefore in case of a breach by one of the con-
tracting parties the damages that the other can recover are
"Roper v. Johnson, L. R. 8 C. P. 167; 42 L. J. R. N.S. C. P. 65.
474 LAW OF DAMAGES.
such as may fairly and reasonably be considéfed as arising
naturally from the usual course of things, or such as may
reasonably be presumed to have been in the contemplation of
both parties at the time they made the contract as the proba-
ble result of the breach of it.’
555. This rule has been recognized and approved by the
courts of England and this country ever since the decision was
rendered. In some cases it has been criticized and questioned,
but in no case has it been entirely disregarded and rejected.’
556. The Court of Appeals of the State of New York in
the case of Griffin vs. Colver, in comment on the question of
remote and speculative damages said: “The broad, general
rule in such cases is, that the party injured is entitled to re-
cover all his damages, including gains prevented as well as
losses sustained; and this rule is subject to but two conditions.
The damages must be such as may fairly be supposed to have
entered into the contemplation of the parties when they made
the contract, that it must be such as might naturally be ex-
pected to follow its violation and they must be certain both in
nature and respect to the course from which they proceed.”®
19 Eng. Exch. 34.
2 9 Exch. 341; Hamilton v. McPherson, 28 N. Y. 72; Woodward v. The
G. W. Railroad Co., 2 L. R. 318; Hamilton v. The G. Northern R. Co.,
1H. & N. 408; Hale v. London & N. W. R. Co., 4 B. & S 66; Gee v.
Lancaster, etc., R. Co., 6 H. & N. 211; Wilson v. L. & Y. R. Co, 9C. B.
632; Collard & 8. E. R. Co.,7 H. & N. 79; Boyd v. Fett, 14 Irish L. 43,
Dunlope v. Higgins, 1 H. & L. Con. 381; Smeed v. Foord, 1 El. & El
602; Krom v. Long, 48 N. Y. 689; Shepard v. Milwaukee Gas Light Co ,
15 Wis. 318; Hinkly v. Beckwith, 13 Wis. 31; Abbott v. Gatch, 13 Md.
314, Copper v. Copper Min. Co., 33 Vt. 92; Ashe v. DeRosett, 5 Jones
(N. C.) 299; Baldwin v. Bennett 4 Cal. 392; Page v. Ford, 12 Ind. 46;
Adams Express Co. v. Egbert, 36 Pa. St. 360; Pittsburg Coal Co. v. Fos-
ter, 59 Pa. St. 365; Wolf v. Studeybaker, 65 Pa. St. 459; Phaland v.
Ardens, 52 Ill. 486; M. Manufacturing Co. v. Quentain, 107 Mass. 127;
Booth v. Spagler Dunghill Mill Co., 60 N. Y. 487. :
316 N. Y. 489; Develin v. Mayor, 63N. Y. 8; Booker v. Goldsborough
PERSONAL PROPERTY, 475
557. The General Rules Deduced from all the Authorities. After
the examination of the leading authorities in this country and
in England, we have for convenience concluded to give all the
rules laid down for the assessment of damages in an action for
a breach of contract for the sale and delivery of personal
property :
1. Where the price has not been paid in advance and the
vendor fails to deliver the property that he has sold to the
vendee at the time and place fixed by the contract, in an ac-
tion on such breach the vendee can recover the difference be-
tween the contract price and the market value of the property
at the time and place of delivery... The market value in this
rule is considered equivalent to the property itself. From this
amount of property is deducted the contract price, as payment
has not been made; and this reduces the damages to an old,
well settled rule, “that the amount which would have been
received if the contract had been kept is the true measure of
damages if the contract is broken.
2. If suit is instituted without unreasonable delay on the
44 Ind. 490; White v. Miller, 71 N. Y.118; Messmore v. N.Y. Shot &
Lead Co, 40 N. Y 422.
“Kent v. Genter, 23 Ind. 1; Clark v. Pennig, 7 Cow. 681; Frank v.
Satman, 36 Ind. 259; Dana v. Field, 12 N. Y. 220; Field on the law of
dam., 232; McKnight v. Dunlope, 1 Seldon (N. Y.) 537; Billings v. Van-
derbeck. 23 Barb. 545; Zenker v. Dale, 25 Ind 433; White v. Thompkins,
52 Pa St. 363; 3 Parsons on Contracts, 205; Pillfrath v. Evans, 5 M. &
W. 475; Rand v. W. Mount. R.. Co., 40 N. H. 79; Cannon v. Folsom, 2
Ia. 101; Crosley v. Watkins, 12 Cal. 85; Bartlett v. Blanchard, 13 Gray
429; Barnard v. Conger, 6 McClane 497; 6 Wheat. 109-118; 2 Wend. 399-
407; Harper v. Smith, 3 Cow. 82; Davis v.-Shields, 24 Wis 322; Arnold
v. Suffolk Bank, 27 Barb. 424; Clark v. Penn, 7 Cow. 681; Davenport v.
Wells, 1 Ia. 598; Canon v. Folson, 2 Ia. 101; Randon v. Barton, 4 Tex.
289; Collin v. McFadden, 13 Tex. 324; Stewart v. Price, 3 Tex. 715.
5 Frank v. Tatman, 36 Ind. 259; Kountz v. Killpatrick, 72 Pa. St. 22;
Wordon v. Norris, 49 N. H. 376.
476 LAW OF DAMAGES
breach of a contract for a failure to deliver personal property
that has been sold and paid for in advance, the measure of
damages will be the highest market value of such property at
any time between the contract time for the delivery, and the
time of the trial But if the suit is not brought within a
reasonable time, and the property has not been paid for in ad-
vance, then the vendee can only recover the highest market
value of such property at any time between the breach and
the commencement of the action. For the reason for this rule
see anti-section 499.
3. Where personal property has been sold and the price
paid in advance, and the vendor has failed to deliver it at the
time and place agreed upon, in an action by the vendee on
such breach he can recover the market value of the property
at the time and place it should have been delivered.‘
4. And where personal property purchased from a vendor
and which he has failed to deliver at the time and place agreed
upon, has no market value, then the true measure of damages
in an action for a breach of the contract is the actual loss the
* Kent v, Gentry, 23 Ind. 1; Clark v. Pery, 7 Cow. 681; Frank v. Tat-
man, 36 Ind. 259; Clark v. Penny, 7 Cow. 681; West v. Wentworth, 3
Cow. 822; Conn. 488; 4 Texas 289; 2 Iowa 201; 6 Georgia 530; 20 Ala.
694; 1 Nott. & McCord 334; Shephard v. Hampton, 3 Wheat 200; West
v. Pritchard, 19 Conn. 211.
If a suit is instituted with reasonable diligence the plaintiff, in case
the price is paid in advance, can recover the highest market value of
the property between when it should have been delivered and the ren-
ditition of the judgment. Kuntz v. Killpatrick, supra.
5 See authorities above.
® This rule is recognized and adhered to by the courts of several of the
States. Beckel v. Colton, 41 Miss. 368; Haskell v. Hunter, 23 Mich. 305;
Northrup v. Cook, 3 Mo, 125; Ward Burr; 5 Blackf. (Ind.) 116; Startup v.
Cortarri, 2 Compt. Mus & Roscoe Exch. R’s 165; 3 Sanford 8. C. R. 614;
3 Mass. Rep. 364; 16 Pick. 194; 5 Watts & Serg. Rep. 106; 11 Seg. & R.
452; 2 Kent (6 ed.) 480; Field on the law of dam. sec. 246.
PERSONAL PROPERTY. 477
plaintiff has sustained by reason, of the defendant’s default.
And this rule applies whether the price is paid in advance or
not. And it is generally adopted by the courts of this coun-
try and England.’
5. Where personal property is sold for the purpose og
enabling the vendee to fulfill an existing contract for re-sale
at an advanced price, which the seller is informed of at the
time of the purchase, in an action by the vendee for a failure
of the vendor to deliver at the time and place stipulated for
in the contract, the measure of damages is the profits the
plaintiff would have realized from the re-sale. This rule is
based on the idea that the parties, when they mide the con-
tract, had in contemplation the consequential result of the
breach of it. And the rule is generally adhered to, both in
this country and in England.’
558. Damage for Failure to Deliver Stocks. For many years
there was a strong tendency among law writers and courts to
make a distinction between stocks and other property. The
7 Kountz v. Kirkpatrick, 72 Pa st. 376; Forsythe v. Palmer, 2 Harrors
97; Montgomery v. Reese, 2 Casey 146; Trout v. Kenedy, 11 Wright 393;
Begdenberg v. Welsh, Baldwin Rep. 331; Suydom v. Jenkins, 3 Sandf
N. Y. 641; Hinde v. Liddell, L. R. 102 B. 265.
1 Messmorse v. S. & L. Co., 40 N. Y. 462: Borries v. Hutchison, 18 C.
B N. 445; Hinde v. Liddell, L. R. 102 B. 265.
In this case where the defendant, being informed that certain shirt-
ings, to be manufactured according to sample, were’ intended for ship-
ment, contracted to supply the plaintiff with them at an agreed price, hy
a fixed date, and shortly before the day notified the plaintiff that he
could not supply them within the time and there were no other goods
of the kind in the market; and the plaintiff. to fiulfill his contract with
his sub-vendee, had to buy elsewhere at a higher price, goods which
were better, but were in quality and price the nearest obtainable to those
contracted for, he was allowed to recover the difference between the
price he had contracted to pay the defendant and that he was forced to
pay elsewhere.
478 LAW OF DAMAGES.
reason that they assigned for the excepticen not being consid-
ered valid, the more modern commentaries and decisions have
refused to recognize the doctrine and have placed stocks on the
same footing of other personal property. Judge Sedgwick, in
his excellent work on damages, says: ‘There appears to be
no solid reasons for making any differénce between stocks and
any other vendable commodity. Where stocks are loaned, or
the price of the stock or other article is paid for, the party en-
titled to the delivery parts with his delivery on the faith of
the contract, and in either case is prevented from using it up
to the time of the trial. The question is, whether in either
case the law should act on the assumption that the plaintiff
would have retained the property if the contract had been
complied with till the period of the highest value, and have
realized that price, and thus give damages which are purely
conjectured.”? But notwithstanding the conflict and confu-
sion among authorities, we think it may now be laid down as
a general rule, upheld by the weight of authority, that where
stocks have been sold and paid for in advance, and the defend-
ant fails to deliver them according to contract time and. place,
the plaintiff may recover their highest market value up to the
time of the trial. The rule allowing the highest market
value of the article up to the time of the trial, rests on too
many violent presumptions to be altogether ‘satisfactory. It
must be presumed: 1. That the plaintiff has parted with his
money for the stock. 2. That he obtained it as a permanent
investment. 3. That he would have retained it until the time
of the trial. When each of these presumptions is as baseless
2 Sedg. on dam. 273.
s Field on the law of damages, 257; Downer v. Black, 1 Stark 318; Har-
rison v. Harrison, 1 C. & P. 412; Ocum v. Routh, 140. B (5 J. C. Scott)
537. The courts of several of the States still insist, with a great deal of
earnestness, that the old rule should still be adhered to, and the differ-
ence kept up. Field on law of damages, 227. ;
PERSONAL PROPERTY. 479
as the fabric df a dream, and the rule, instead of being gen-
erally fixed and certain, is merely speculative, conjectural and
dependent on accidental circumstances.‘
559. The Market Value. The only object that courts have
in considering the matket value of an article in estimating the
plaintiff’s damage, is for the purpose of arriving at his actual loss
and award him full compensation. The market value is not
itself the value of the article, but is only evidence of its value.
It stands as a criterion of value because it is a common test of
the ability to purchase the thing of others; and to assert that’
‘the price asked in the market for an article is the true and
only test of value, is to abandon the proper object of damages
—full compensation for all loss sustained. The rule has been
adopted for its convenience, and from the further fact that it
generally answers the object of the law, which aims to com-
pensate for the injury. But it is manifest that this rule can
not, without great hardship, be universally adopted; for there
are many articles that have no market value at all. But
courts would not from this fact alone be justified in saying
that the article is of no value. It is evident that the market
value is not an invariable standard; and it sometimes hap-
pens, and especially is it true in the sale of stocks, that the
market value is unnaturally inflated by unlawful and fraudu-
lent practices, so that it cannot be the trué means of ascer-
taining what is a just compensation. On the other hand, the
4 Stuart v. Kieth, 57 Ill. 451.
We think it may be laid down as a rule that the plaintiff, in an action
to recover damages for the uon-delivery of stocks at the time and place
designated by the contract, will be entitled to have his loss assessed in
the s:me way that they are assessed in other cases of the same chara ‘-
ter. and for other property. See authorities above. Arnold v Suffolk
Bank, 27 Barb. 424, Barnard.v. Hamilton 2 Rankin cos 624; Shaw v.
Holland, 15 H. & W 136 But in Indiana and Pennsylvania the dis-
tinction between stocks and other merchandjse is still kept up Mont- ,
gomery v. Reese, 26 Pa. st. 148; Kent v. Genter, 23 Ind. 1.
480 LAW OF DAMAGES.
price of an article is very frequently reduced below its actual
value by the same means; so that the rule allowing the plain-
tiff the highest market value up to the time of the trial ap-
plies only in case of those articles that have a market value,
and does not apply to goods that have no such value.’ In
determining what is the market value of property at a par-
ticular time, the jury are sometimes authorized to take a wide
range, for in some cases this value is not always ascertainable
by perceived fact, but must rest on opinion, and the law will
not allow either party to gain by mere inflated or fancy prices.
Therefore, where there is an inflated or accidental value sud-
denly put in force-by some speculative movement, and as sud-
denly passing away, it cannot be allowed as the true test of
the plaintiff’s damage. The law, in regulating the measure
of damages, contemplates a range of the entire market and
adopts the average price thus found, running through a rea-
sonable period of time.®
560. The Damages where the Vendee Fails to Comply. In an
action for not accepting goods that have been purchased, the
measure of damages is the difference between the contract
price and the market value or price on the day when the ven-
dee ought to have accepted the goods. This rule is based on
the principle that the vendor shall be fully compensated for
all loss sustained by the default of the vendee, and is upheld
by the weight of authority.’
. Suydam vy. Jenkins, 3 Sandf. N. Y 641; Clark v Penny, 7 Cow. 68;
Field on the law of damages Sec. 250.
® Kountz v. Kirkpatrick, 72 Pa st. 376.
* Pitt., Cin. & St. L. R. R. Co. v. Heck, 50 Ind. 303; Williams v. Jones.
1 Bush. 621; Haskill v. McHenry, 4 Cal. 411; Allen v. Janis, 20 Conn. 38;
Northrup v. Cook. 39 Mo 208; Gatting v. Newell, 12 Ind 118-125; Beard
v. Sloan, 38 Ind. 128; Ganson v Moding, 13 Wis 67; Gordon v. Norris;
49 N. H 376; Chittg. on Contract, 11 Am ed. 1331.
PERSONAL PROPERTY. 481
561. Damages for Failure to Accept Goods Manufactured for a
Certain Purpose. Where goods are manufactured after a partic-
ular fashion, or in a particular way, according to order, and the
vendee refuses to take them at the stipulated time and place,
and the vendor brings an action for damages, he can recover
the difference between the contract price and the value of the
property when it should have been expected. The reason for
the departure from the ‘general rule in this class of articles or
goods is that they have no market value or price.*
562. Damages where Article is Manufactured to Order. But
where an article has been prepared, such as a statue or a:pic-
ture of a particular person, to order, or where a mechanic
makes a specific article in his line, to order and after a particu-
lar measure, pattern or style, or for a particular use or purpose,
where he has fully performed his share of the contract, and
tendered or offered to deliver the article thus manufactured
according to contract, and the vendee refuses to receive and pay
for the same, the plaintiff may recover the full contract price.’
563. Damages where a Part of the Property Has Been Delivered.
The old rules of the common law, as interpreted by the courts
of this country a half century ago, were such that if the ven-
dor of personal property contracted to deliver an entire lot or
quantity of property or goods for a specified price, he could
5 Pitts etc. R. R. Co. v. Heck, 50 Ind. 303; Gordon v. Norris, 49 N. H
376; Old Colony R. R. Co. v. Evans, 6 Gray 25; Griswold v. Sabein, 51
N.H. 167: Bement v. Smith, 15 Wend. 4938 The rule of damages is the
same as in breach of contract for the sale of real estate. Pitts. etc. R.R.
Co. v. Heck, supra. See Porter v. Travis, 40 Ind 556.
2 Pitts., OC. & St. L. R. BR. Co. v. Heck, 50 Ind. 303; Allen v. Jamis, 20
Conn. 38; Bement v. Smith, 15 Wend. 493; Ballantine v. Robinson, 26
Pa. 177; Gordon v. Norris, 49 N H. 876; McCormick v. The N. Y. & E.
R. R. Co, 20 N. Y. 495; Dustan v. McAndrews; 44 N. Y. 72-78. The
same rule applies on the delivery of any other class of goods.
482 LAW OF DAMAGES.
not recover for any quantity delivered less than the whole?
Thus, if one engaged to deliver to another one thousaud head
of fatted hogs for ten thousand dollars, and he delivered under
the contract nine hundred and ninety-nine of the hogs, and
failed to deliver the last one of the thousand, he could recover
no part of the purchase money. This old, severe rule, that is
so much in conflict with the principles of right and justice,
is being modified in such a manner as to give the vendor right
of action for what the property delivered is reasonably worth,
but the vendee may recover his damages for the breach of con-
tract to deliver the whole of ‘the goods.’
This is bringing the rule down to the old familiar maxim
that is so universally recognized by the great mass of the peo-
ple, “that a man sha’nt have something for nothing” And
we think that the time is not afar distance in the future when
this maxim will be adhered to everywhere.
566. The Liberal Doctrine Recognized. The doctrine laid
down in the preceding section is now fully or partially recog- .
nized in Indiana, Michigan, Wisconsin, Illinois, Pennsylvania,
Maine, Texas, Tennessee, Missouri, New York and other States.’,
3 Dermont v. Jones, 2 Wall 1.
42 Parsons on Contract 35; Baker v. Hoyt, 18 Peck 555; McKinny v.
Springer, 3 Ind. 59; Epperley v. Baily, Ia. supra, 72; McCluer v. Secrist,
5 Ind. 31; Ricks v. Yates, Ia. 115; Wheatly v. Meascol, 5 Ind. 142-261;
‘Britton v. Turner, 6 N. H 495 481; Pexler v. Nichols, 8 Ia. 106; McCoy
v. Hedges, 18 Ia. 66; Dawes v. Fish, 1 G. Greene (Ia.) 406; Crooksacks
v. Malory, 2 Ia. 257, Eyser v. Weissegeiler, Ia. 463; Mitchell v. Wiscotta
Land Co., 3 Ia. 209; ‘Tice & Mc. v. Sherman, 10 Ia 60; Cornur v Wall,
17 Ia 374; McAffee v. Hale, 24 Ia. 355; Field on the law of dam., Sec
332, 333, 334.
5 Wiley v. Hack; 25 Mich. 419; Bishop v. Price, 24 Wis 480; Trolenap
v. Barrett. 30 Wis. 661; Jones v. Jones, 2 Swan Tem. 605; Edington v.
Pick, 1 Smeed Tenn. 122; Allen v. Kibber, 5 Mich. 444; Davis v. Baring-
ton, 10 Fost N H. 517; Sinclair v. Talmage, 35 Bash. N. Y 602; Neb>v.
Browhn, 24 Ill. 268; McKing v. Springer, 3 Ind. 59; Dermont v. Jones,
23 How. 220; Western v. Sharp, 14 B. Mon. Ky. 177; Lamb v. Brolaski
88 Mo. 451; Newman v. McGregor, 5th Ohio st. 349.
CHAPTER XXXIIL
CONTRACTS FOR SERVICES.
DAMAGES IN CASE OF BrEAcH OF ContTRACT TO PERFORM SER-
Vick. THE DECISION ON THE SUBJECT. DAMAGES IN CASE OF
BREACH BY THE EMPLOYER. DAMAGES IN CASE OF BREACH
BY THE EMPLOYE.
567. The Division of the Subject. In the discussion of
the question of the measure of damages for a breach of con-
tract for services, we propose to notice: 1. The damages
arising érom a breach of contract by the employer. 2. The
measure of damages on account of the breach of the contract
by the »mploye. But before we proceed to notice the questions
in detail, we desire to say that the law never attempts to make
contracts for parties; its only office is to enforce them. It pre-
sumes that every individual is sui juris, or capable of man-
aging his own affairs. It holds out every reasonable induce-
ment to encourage men to engage’ in enterprises that will be
remunerative to them and beneficial to the State. In doing
484 ‘ LAW OF DAMAGES.
this it never releases an individual from a contract or vbliga-
tion entered into by him with a full knowledge of all the facts.’
Therefore where work is done under special contract, fix-
ing the price to be paid thereof, as a rule the contract will
control the price, and the question whether it is reasonable or
unreasonable will not be considered; and in an action on such
agreement the plaintiff can recover the amount stipulated to
be paid, or the unpaid balance due by the terms of the con-
tract... “But if there is no agreement as to price of the service, ,
then the employe may recover so much as t.1e services are
reasonably worth.” ”
568. Where one has entered into a contract to labor for
another, and the employer refuses to accept the labor of the
employe, and forbids him to perform it, the contract is bro-
ken, and the employe has a complete cause of action. He has
however, two remedies growing out of the wrongful act.' He
may treat the contract of hiring as continuing, though broken
by the employer, and may recover damages for the breach.
He may rescind the contract, in which case he can sue on the
quantum merwit for services actually rendered. These reme-
dies are independent of an additional to his right to sue for a
' This rule is subject to a few exceptions. It is based on the supposi-
tion that all parties are capable of making contract, while children feme
coverts, and insane persons are not. :
‘Clark v. Mayor, N Y. 4 N. Y. 338; Bingham v. Howly, 17 Ul. 38
McClelland v. Snider, 18 Ill. 58.
° Field on the law of dam. sec. 323; Frazer v. Gregg, 20 Ll]. 299; Gra-
ham v. Graham, 34 Pa st. 475; Westen v. Sharp, 14 B. Mon 177.
In the case of Street v. Swaine the court below instructed the jury
“that if there was a finding for the plaintiff the measure of damages
would be the price agreed upon, or if there was no price, then the rea-
sonable value of the material and work, 21 Ind, 203.
' Howard v. Daly, 61 N. Y., 362.
CONTRACT FOR SERVICES. 485
a sum actually earned and due by the terms of the contract.
This last amount he recovers because he has completed either
in full or'\in a specific part the stipulation betweeu the parties.
The first two remedies pointed out are appropriate to a
wrongful discharge. Under the first remedy mentioned the
plaintiff must hold himself in readiness to perform. If that
readiness exists at Uhe time set for the service to commence,
and the defendant committed a default, a further tender of per-
formance is not necessary in order to recover. For it is a rule
that a tender of performance is not necessary where there is a
willingnessand ability to perform, and actual performance has
been prevented or expressly waived by the party to whom per-
formance is due?
569. The Duty of a Dismissed Servant to get other Employment.
The law makes it the duty of a dismissed servant to use rea-
sonable exertions to get other employment. And on the trial
of the cause the court will presume that the employe has dis-
charged his duty in this respect. And if suit has been brought
after the time of service has expired, the plaintiff will be en-
titled to recover the contract price for the full time, unless the
defendant can show that he has, or might have by reasonable
diligence, procured employment elsewhere, in which case the
measure of damages will be the difference, if any, between the
contract price and the price he has, or might have, received
elsewhere.’ But where suit is brought before the expiration
4
2 Francot v. Leach, 5 Cow , 506; Cost v. Ambergot R. R. Co., 17 A. &
E., N. §., 127; Nelson vy, Pleppfton Fire Proof E. Co; 55 .N. Y., 480;
Howard v. Daley, 61 N. Y., 363.
32 Greenleaf on evid. s., 261; Cortegon v. Mana H. R. R. ‘Co., 2 Den.,
609; Howard v. Daley, 61 N Y., 362; Hunt v. Crane, 33 Miss., 669;
Prichard v. Mastin, 27 Miss., 306; Danby v. Williams, 16 Wis., 681;
Stunburg v. Gilchrist, 41 Mo., 520; Thompson v. Wood, 1 Hilt., N, Y.,
594; Nearn v. Harbert, 25 Mo., 352; Pond v. Wyman, 15 Mo., 175; Has-
sel v. Nutt, 14 Tex., 260; Nations v. Cndd, 22 Tex., 550.
486 LAW OF DAMAGES.
of the contracted time for the performance of the service, the
employe can only recover pro rata to the time suit is brought.‘
570. The Act of God. All human laws are, or should be,
auxiliary to the divine law, or the laws of God. And the
courts take judicial notice of the workings of the laws of
nature upon all sublunary creatures. Therefore it may be laid
down as a general rule that the act of God, which prevents an
individual from fulfilling an engagement to perform labor, as
death, will excuse him from performing the same at law ; and
where one engages to perform labor for another, and after a
part performance dies, his representatives may recover from
the employer pro rata for the time employed, or the amount of
service rendered, according to the price stipulated to be paid;
or if no price is stipulated for, then on the quantum mesuit, with
a deduction of the damages sustained by the employer in con-
sequence of the employe not being able to complete the full
term. And it is well settled that neither party to an execu-
tory contract shall be injured by either death or sickness, or
from natural or unavoidable causes. Actus Dei nemini foeit in-
jurt am?
*Where an employer, without sufficient cause has dismissed the ser-
vant before the end of his term, the servant can only recover the value
of his services to the time he was dismissed, and the damages he has
suttained by the dismissal- Ricks v. Yates, 5 Ind., 115; Jones v. Van-
pattent, 3 Ind., 107; Wright v. Falkner, 37 Ala., 274; William v. Chicago,
60 Ill., 149; Ream v. Watkins, 27 Mo., 516.
5 Coe v. Smith, 4Ind. 79; Tomax v. Baily, 7 Black 599; Milnes v. Van
Horn, 8 Black, 198; Fenton v. Clark, 11 Vt. 557.
Where A contracted with B to labor for him four months froma given
day, at $10 per month, and to receive no pay until he had worked the
four months, and was prevented from completing the four month’s labor
by reason of sickness, he might recover, upon a quantum meruit, for the
service performed. Fenton v. Clark, 11 Vt. 557; Seoner v. Moron, 20 Vt.
620; see Farrow v. Wilson, 4 L R. P. 744; Boast v. Frith, Ia.1; Wolf v.
Howe, 20N. Y. 197; Jones v. Judd, 4 N.Y. 412; Doter v. Brown, 25 Ga.
24; Fuller v. Brown, 11 Mich. 440; Hule v. Belden, 27 Vt. 645; Allen v.
. McKibbin, 5 Mich. 449; Clark v.. Gilbert, 26 N. Y. 279.
CONTRACTS FOR SERVICES, 487
571. Breach of Contract by the Employer. Where an execu-
tory contract has been broken by the employer, the employe
may maintain a suit for damages arising from such breach,
and the measure of his recovery will be all the loss sustained
by reason of such breach or default, and this includes gains
that he would certainly have made.’ But the rule in refer-.,
ence to the recovery of profits will be limited to such as would
have accrued and grown out of the contract itself, as the direct
and immediate fruits of its fulfillment. Such profits are con-
sidered a part or a parcel of the contract itself, entering into
and constituting a portion of its very elements. Something
stipulated for, the right to the emjoyment of which is just as
clear and plain as the fulfillment of any other stipulation.
The court will presume that they were taken into considera-
tion before the contract was made, and formed perhaps the
only inducement to the contract.*| Thus in the case of Morri-
son v. Lovejoy, which was an action brought by the plaintiff
against the defendant for a breach of contract to pay for saw-
ing lumber, and for the failure of the defendant to furnish the
plaintiff with logs to be sawed into lumber pursuant to a con-
tract between them. The court, in rendering its opinion,
said: ‘Where one party to an executory contract, like that
on which this action is brought, refuses further to comply with
it on his part, the other party has an immediate cause of
action for said breach, and he may sue on it at any time and
recover the damages which he may have sustained by being
deprived of the benefit accruing to him under it. If he treats
the contract as ended, and sues immediately upon its breach,
his damages are to be measured by the value of the contract
5 Fail v. McKee, 36 Ala. 61; Fox v. Hadding, 7 Cushen 516; Cunning-
bam v. Dorsey, 6 Cal. 18; May on dam. 16.
“ Masterdon y. Mayor of Brooklyn, 27 Hill (N. Y.) 61. Stoy v. N. Y. &
Harlan R. R. Co., 6 N. Y. 85; Seaton v. Municipality, 3 Lend Ann, 44;
Dunn v. Johnson, 33 Ind. 54.
488 LAW OF DAMAGES.
to him at the time it was broken, and this value is estimated
by the profits he would have realized during the continuance
of the contract had it been faithfully carried out by the par-
ties. But in estimating the profits which a party under such
a contract would realize, allowance must be made for any item
of costs and expense necessarily attending a full compliance
on his part. If, therefore, the eontract is for manufacturing a
-given article, and mills or machinery are necessarily employed
in making it, the reasonable or usual rent or value of the use
of such mill or machinery enters into the costs of manufac-
turing, and should be taken into consideration in estimating
the profits, because the profits are distinctly affected by such
expense as by any other.’*
572. Damages where there Has Been a Part Performance. It
was thought for years that the common law gave an employe
no remedy where he undertook to perform an entire contract
for a specified price, and he voluntarily left his employer’s
service before the expiration of the period contracted for! But
in most of the States this rule, that seems to have been
adopted more for the punishment of those who failed to com-
plete their term of service than to give to each person their
just due, has been set aside. And now a person who has
abandoned the service of another before the expiration of the
time, may recover upon the common count for work and labor
to the extent of the benifit of his services actually rendered
was to his employer, over and above the damages his failure to
comply with his contract occasioned.
4 Morrison v. Lovejoy, 6 Minn. 319.
1 Ricks v. Yates, 5 Ind. 115; McMillen v. Vanderbig, 12 John. 165;
Thorp v. White, 13 John. 326; Jennings v. Camp, 13 John 94; Clark v'
Smith, 14 Johns. 326; Keab v. Moore,19 John. 337; Henson v. Hamp-
ion, 82 Mo. 408; Pory v. Garth, 7 Mo. 94; Dickson v. Caldwell, 17 Mo.
575; Ellis v. Hamlin, 3 Taunt. 52.
* Ricks v. Yates, 5 Ind. 115; Britton v. Turner, 83 Vt. 35; Dyer v
CONTRACTS FOR SERVICES. 489
573. But it should be remembered that in order for the
employe to recover, the employer must have accepted either di-
rectly or indirectly the products of the labor. Thus in the
case of Britton v. Turner, the Supreme Court of New Hamp-
shire, in commenting on the question, after alluding to cases
establishing the doctrine that in building contracts which had
not been strictly complied with, the party for whom the work
had been done, and who had been benefitted thereby, was liable
for a reasonable value of the work, says: ‘Those cases are not
to be distinguished in principle from the present, unless it be
in the circumstances that where a party has contracted to fur-
nish the material and do certain labor, as to build a house in a
specified manner, if it is not done according to contract the
party for whom it is built may refuse to receive it, and elect to
take no benefit from what has been performed, and therefore,
if he does receive it, he shall be bound to pay, whereas; in con-
tracts for labor merely from day to day the party is continual-
ly receiving the benefit of the contract under the expectation
that it will be fulfilled, and cannot, upon the breach of it have
an election to refuse to receive what has been done, and thus
discharge himself from payment. * * * The party
who contracts for labor merely for a certain period, does so with
t
Jones, 8 Vt. 205; Gillman v. Hall, 11 Vt 510; Brackett v- Morris, 23 Vt.
554; Morris v. Cummings, 26 Vt. 645; Hubbard v. Belden. 27 Vt. 645;
Baker v. The Troy Rutland R. Co., 27 Vt. 645; Swift v. Harriman, 30 Vt.
607; 2 Pars. on Cont. 35; Thqmas v. Dike, 11 Vt. 273; Dorcher v. Conti-
nental Mills, 50 Md. 217; Jones v. Jones, 2 Swann (Tenn.) 605; Britton
v. Turner, 6 N, H. 495-481; Pixly v. Nichols, 8 Ia. 106; McCoy v. Hedges,
18 1a. 66; Davis v Fish, 1 G. Green (Ia.) 406; Crookshanks v. Mallory,
2 Ia. 257; Eyser v. Weissgesler, ib. 463; Mitchell v. Wescott Land Co.,
17 Ia. 314; McAffee v. Hale, 24 Ia. 335; Wely v. T. Sch. Dist. No. 1, 25
Mich. 419; Bishap v. Price, 24 Wis. 480; Trobridge. v. Barrett, 30 Wis.
661; Edgerton v. Peckle, 1 Smed. 122; Allen v. McCelelur, 5 Mich 449;
Sinclair v. Talmage, 35 Barb. 602; Niles v. Brauhn, 24 IIl. 268; "McKin-
ny v. Spring, 3 Ind. 59; Dermont v. Jones, 23 How. 220; Wstern v.
Sharp, 14 B. Mon. 177; Lamb v. Broloski, 38 Mo. 51; Newman v. Mc-
Gregor, 5 Onio st. 349.
490 LAW OF DAMAGES.
a full knowledge that he must, from the nature of the case, be
accepting part performance from day to day if the other party
commences the performance, and with a knowledge, also, that
the other party may eventually fail of completing the
entire term. If, under such circumstances, he actually re-
ceives a benefit from the labor performed, over and above the
failure to complete, there is much reason why he should pay the
reasonable worth for what has been thus done for his benefit,
as there is when he enters and occupies the house which has
been built for him, but not according tu the stipulations of the
contract, and which he, perhaps, enters, not because he is sat-
isfied with what has been done, but because circumstances
compel him to accept it, such as it is, that he should pay for
the value of the house. It is said that in this case, where the
plaintiff has been permitted to recover, there was an accept-
ance of .what had been done. The answer is that where the
contract is to labor from day to day for a certain period, the
party for whom the labor is done in truth stipulates to receive
it from day to ‘day as it is performed; and, although the other
may not eventually do all he has contracted to do, there has
been necessarily an acceptance of what has been.done in pur-
suance of the contract, and the party must have understood
when he made the contract that there was to be such accept-
ance. * * * Tf, on failure to perform the whole, the
nature of the contract is such that the employer can reject
what has been done and refuse to receive any benefit from the
part performance, he 1s entitled to do so, and in such case he is
not liable to be charged, unless he has before assented to and
accepted of what has been done, however much the other
party may have done towards the performance. * * *
But when the party receives value and takes and uses the ma-
terial, or has advantage from the labor, he is liable to pay the
reasonpble worth of what he has received. And the ruleis the
same whether it was received and accepted by the assent of the
party prior to the breach under a contract by which, from its
CONTRACTS FOR SERVICES. 491
nature, he was to receive labor from time to time until the
completion of the whole coutract, or whether it was received
and accepted by assent subsequent’ to the performance,,all of
which -was in fact done. If he received it under such -circum-
stances as precluded him from rejecting it aftewards, that does
not alter the case—it has still been received by his assent.’”
574. What will we Consider an Acceptance. Where the em-
ployer during the progress of the work stood by and from time
to time objects to the material and the manner in which the
work is being performed, but acquiesces in the progress of the
work, and finally refuses to: accept it when completed, the
court held that if the work was beneficial to the defendant he
was liable for the material and labor, not on the contract, but
on general counts in the assumpsit.”
575. Charge and Special Work. Employes who contract
for the construction of large buildings generally make their
contract to build according to certain specifications furnished
by theiremployers. And it frequently happens, after the work
has progressed for a time, that the employer desires to make
some alteration, or a deviation from the original plin, and in-
structs the employe accordingly. If there is no agreement as
to what shall be the price of the extra work, the jury, in
assessing damages for such work, should be governed by the
original contract price as far as possible; but if its provisions
cannot pe applied, the employe may recover on the quantum
TSN. H.; 481.
™ Hayward v. Leonard, 7 Peck, 181
' Field on Jaw of dam. 305; Brigham v. Hanely, 17 Ill. 38; Meash v.
Richards, 29 Mo 99; Mend v, Ithica & Oswego R. Co, 16 Wend. 586;
Sedg. on dam 221; McClelland v. Snider, 18 Ill. 58; Weslen v. Shaip,
14 B. Mon. 177; Goodard v. Barnard, 82 Mass. 205; Peters v. Whiting, 23
Barb. 24. ‘
492 LAW OF DAMAGES.
meruit, or what the work was worth. A deviation by agree-
ment or consent should be looked upon generally as a new
contract, and enforced as such.!
- 576. The Liberal Rule. The principle announced in the
case of Britton v. Turn-r, that we have already noticed, is
gradually growing in favor among the courts of the different
States; and we believe that the weight of the most recent
authorities not only recognize this rule as applicable to con-
tracts to perform manual labor, but to all cases relating to
damages in case of contracts to build, where the contractor is
to furnish the material and perform certain specified work.
Thus in Indiana, where an action was brought upon a special
contract, also for work and labor: By the special contract set
up the plaintiff agreed to chop, clear off, fence and grub twenty
acres of land, described in the contract; the ground was to be
enclosed, and divided into two lots by a running fence through
the middle, with a good fence ten rails high, provided there
was suitable rail'timber on the land tomake the rails; but the
plaintiffs were not to go off the land for rail timber. The evi-
dence shows that the parties entered into the contract as set
forth in the complaint, and that the plaintiff had only par-
tially performed his part of the agreement. The court said:
“A party cannot recover ona special contract which he has
failed to fulfill on his part. * * On the other hand, it is
settled that when one to an entire contract has not complied
with its terms, but professing to act under it has done for, or
delivered to the other party something of value to him, which
he has accepted, the party who has been thus benefitted by
the labor or property of another, shall be responsible, on an
implied promise arising from circumstances, to the extent of
the value received by him.”’? .
* Walcott v. Yeager, 11 Ind. 84; see also Heaton v. Colgrove 3 Ind‘
265; Mayor v. McLester, 4 Ind. 591; Tomax v. Baily, 4 Ind 595; Britton
Turner, 6 N. H. 481.
CONTRACTS FOR SERVICES. 493
577. Also in Iowa, in an action by the plaintiff for work
done and performed, the evidence showed that the plaintiff
was hired by the defendant to work for him for six months,
and left his service after laboring for four months. The court
was, on the trial, asked to instruct the jury that if the plain-
tiff hired to the defendant for six months, and left his service
before the expiration of the term, he had no claim upon the
defendant for the service rendered. The instruction was re-
fused by the court, and there was a judgment for the plaintiff;
appeal to the Supreme Court of that State, where the judg-
ment was affirmed. Stockton, in delivering the opinion of the
Court, said: “We think the instruction was rightfully re-
fused. If the parties had expressly agreed that if the plain-
tiff left the service of the defendant before the expiration of
the time limited, nothing was to be considered as earned by
him, there would be no doubt that the plaintiff cculd not re-
cover. But all that is shown is that upon an agreement to
labor six months, the plaintiff labored for four months and
refused to labor longer, and sues for the value of the labor per-
formed. We think he is entitled to recover as upon a quantum
meruit and need not, as a condition precedent, first show that
he had performed his entire contract or that he had left the
’ service of his employer upon good cause. We are satisfied with
the rule established in Britton v. Turner (6 N. H. 481) giving
its full weight for the protection of the employer in such
cases, with the qualifying rule that where the contract is
broken by the fault of the party employed, after part perform-
ance has been received, the employer is entitled, if he so elects,
to put the breach of the contract in defense for the purpose of
reducing damages or showing nothing is due, and to deduct
what it will reasonably cost to secure a reasonable completion
of the whole service, as well as damages systained by reason of
the non-fulfillment of the contract. If in such a case it is
found that the damages are equal to or greater than the value
of the labor performed, and‘that the employer, having a right
~
494 LAW OF DAMAGES.
to performance of the whole contract, has not received any
beneficial service, the plaintiff is not entitled to recover.” *
578. The same doctrine was adhered to in that State as
applicable to building contracts. The plaintiff entered into a
contract to build the defendant a barn, shed and:corn crib
under a special contract, for one hundred and five dollars, ac-
cording to certain stipulations and within a specified time.
The plaintiff failed to complete the building within the time
agreed upon, and also failed to do the job in a workmanlike
manner. It was found that it would cost twenty-seven dollars
to make the work comply with the contract, and that the
defendant had paid fifty-five dollars to apply on the contract,
and that there was due to the plaintiff twenty-three dollars,
and judgment rendered accordingly. Judge Dillon delivered
the opinion of the court: “This question was settled in this
State by the case of Pixley v. Nichols, 8 Ia. 106, which dis-
tinctly recognized and expressly followed the case of Britton
v. Turner, 6 N. H. 481. That celebrated case has been criti-
cised, doubted and denied to be sound. It is frequently said
to be good equity, but bad law. Yet its principles have been
gradually winning their way into the profession and judicial
favor. It ’s bottomed on justice,and is right upon principle, how-
ever it may be upon the technical and more illiberal rules of
the common laws as found in the old cases. With the knowl-
edge and natural disposition of courts to disfavor the course of
him who has broken his co itract, and yet seeks a recovery;
and with the limitation stated in Pixley v. Nichols, the ap-
plication of this rule will not be found, practically, to work
injustice to the employer or-contracting party who is without
fault. The rule applies to such cases as the one under consid-
eration, i. e., formal acceptance of the work or an acquiesce in
§ Pixler v. Nichols, 8 Ia. 106.
’
CONTRACTS FOR SERVICES. 495
the breach is not necessarily essential to a recovery.”* This
. . ® . . x
doctrine is now recognized in a number of other States®
579. Where the Employer Refuses to Accept the Work under the
Contract. Cases frequently arise where the employe enters upon
the work, pursuant to and in accordance with the contract, and
performs a part of the labor and is prevented by the conduct
of the employer from completing it. In such cases the party
' performing it can sue either on the contract to recover dam-
ages for the breach of it, or on general assumpsit to recover the
value of the work he has done. If he adopts the former rem-
edy he can recover such a portion of the whole contract price
as the work done bears to the whole work, and in addition to
this he, as a general rule, will be entitled to ‘the profits. he
would certainly have made if allowed to complete unperformed
work, and the loss he may have incurred,in employing labor
and means to perforin the residue; but if he sues on the quan-
tum meruit he may then recover reasonable compensation for
the work performed.®
* McCoy v. Hedges, 18 Ia 66; see also Davis v. Fish, 1 G. Green Ia.
406; Mitchell v. Wescotta Laud Co., 3 Ia. 209; Tice & McIntosh v Sher-
man,10 Ia 60; Cannon vy. Wallace, 17 Ia. 374; McAffee v. Hale, 24 Ia.
355. ’
5 Wily v. Frac. Sch. Dist No 1, 25 Mich. 419; Bishop v. Price, 24 Wis,
480; Trowbridge v. Barnett, 30 Wis. 661; Jones v. Jones, 2 Swan 605,
Edington v. Pickel, 1 Sand 122; Allen v. McKibben, 5 Mich. 449; Davis
v. Borrington, 10 Forist N. H. 517; Sinclair v. Talmage. 35 Barb. N. H.
602; Nebe v. Boham, 24 Ill. 268; McKinney v. Springer, 3 Ind. 59; Wal-
cott v. Yeager, 11 Ind. 84; Dermont v. Jones, 283 How 220; Westorn v.
Sharp, 14 B. Mon. Ky. 177: Lamb v. Brolaski. 38 Mo. 57; Newman v.
McGregor, 5 Ohio st. 349; Field on the law of dam. sec. 334.
6 Chamberlain vy. Scott, 33 Vt. 80; Derby v. Johns, 21 Vt. 18; Board-
man v. Keeler, 21 Vt 77; Smith’s Leading Cases, vol. 2, p. 38; Coon v.
Greeman, 7 Wend 121. —
Where suit is brought before the time of service contracted for expires
the plaintiff can only recover pro rata to the time suit is brought.
Wright v. Falkner, 37 Ala 274; Flora v. Danby, 1 ‘Sprague 212; Hunt
v. Collums, id. 215.
496 LAW OF DAMAGES.
580. The General Method for Assessing Damages on Partial Per-
formance. The general rule for estimatink damages where the
employe has for some reason failed to fully perform his contract
is to estimate the actual benefits the employer has received
from the employe’s labor; and to ascertain such benefit the
jury or court trying the cause should find the amount of money
that it will take to complete the work according to the con-
tract, add to this all the damages the defendant has sustained,
by reason of the breach and failure of the plaintiff to comply,
and deduct the amount from the contract price for the whole
work, and the remainder will be the damages.’ But in no
case can the employe who has voluntarily abandoned, or failed
to complete it, recover more than the contract price for the
whole work.!
581. Where suit was brought by the plaintiff, who was a
retailer of intoxicating liquors, under the laws of the State of
Indiana, and being desirous of renewing his license, employed
the defendants, who were publishers of a newspaper, to give
notice that at the next session of the Board of Commissioners,
he would make application for such license. The defendants
failed to make publicationin time. The plaintiff failed, there-
fore, to procure his license and was compelled to close up his
house and suspend business. Suit was brought for damages, i
alleging that he had been damaged at the rate of fifteen dollars
per day for thirty days. The defendant demurred successfully
to the complaint below, and appeal was taken to the Supreme
" Kelly v. Bradford, 33 Vt. 35; Lingdale v. Livingston, 10 John (N. Y.)
36; Jewell v. Schappell, + Cow. 564; Mosford v. Ambros, 3 J J. Marsh
(Ky.) 600; Newmanv MeGregor, 5 Ohio 351; Rogers v. Beard, 36: Barb.
N.Y 31: Wilson v. Graham, 14 Texas 228; Snelling vy. Linch, 5 Allen
Mass. 443; Morrison vy Lovejoy, 6 Minn. 319; Woodbury v. Jones, 44 N.
H. 206; Masterton v. Mayor. etc., 7 Hill 62; Doolittle v McColough, 12
Ohio st. 360; Trobridge v. Sherman, 10 Ta. (0.
‘Walcott v Yeager, 11 Ind. 84; Western v Sharp, 14 B. Mon. Ky.
177; Coe v. Smith. 4 Ind. 79; Field on the law of damages, Sec. 337.
oe
CONTRACTS FOR SERVICES. 497
Court, The court, in commenting on the question arising on
the demurrer said: “It is contended by the appellees that the
complaint at most but shows a case for nominal damages.
This court would not reverse a case, perhaps, where nothing
more than nominal damages are involved, but where a consid-
erable amount of costs, or other legitimate expenses depend
upon nominal damages which are wrongfully denied the party,
. it might become proper for reversing a judgment. But weare
not convinced that each of the paragraphs in this complaint
entitle the defendants to only nominal damages. Nominal
damages are such as a party is entitled to for a mere nominal
breach of his contract, where no actual damages have been
suffered—damnum absque injuria—and may be a cent, five cents
or a dime, or such insignificant sum in relation to the case as
would fall within the maximum de minimus non curatur In
this case, however, the appellant alleges that he paid the ap-
pellee three dollars and a half for inserting the advertisement,
which was never inserted, We think he is entitled by the
facts averred to recover this amount at least, We cannot bold
that three dollars and a half, in reference to the present case, is
no more than nominal damages, especially where a considera-
ble amount of costs must depend upon them. And we think
if, in consequence of the facts averred, the complainants have
and fixtures therein, and place of business became useless to
him for a time that it is a fair element for a jury to consider in
estimating damages the appellant may have suffered, and per-
haps there may be other proper grounds for damages which we
do not mention, but we are of the opinion that the mere prob-
lematical, uncertain, contingent, vague and speculative profits
upon expected sales of liquors by retail, which may or may not
be made, do not constitute a true basis on which to assess dam-
ages.’
3 Glass v. Garber, et al, 55 Ind.; 336.
498 LAW OF DAMAGES.
582. Breach of Contract by the Employe. The rule is pretty
generally settled that the employer, on a breach by the em-
ploye of an excesstory contract to perform labor or do a speci-
fied thing, may recover in an action full compensation for all
loss sustained, including profits that would have been the
direct and immediate result or fruits of the contract. Thus
where the defendant agreed to build and deliver to the plain-
tiff within a specified time, two hundred or more sewing ma-
chines of the model to be furnished him by the plaintiff; breach
of the contract and failure to deliver the machines. Action
was brought to recover damages for the default. The court held
that the measure of damages was the difference between the
market value of such machines at the time they were to be
delivered and the contract price, and that the fact that the
defendant had a patent on the machines made no difference in
the rule.*
583. The General Rule. It may be laid down perhaps as a
general rule that in cases where a suit is brought by the em-
ployer against the employe for a breach of an executory con-
tract to perform labor, job work, or to do a specified t.ing, the
measure of damages will be the difference between the con-
tract price of the work to be done and the usual and ordinary
price.
584. Thus when the defendant entered into a contract to
saw all the timber on the plaintiff’s land, and failed to fulfill
the agreement, the court held, in an action by the employer,
+ Brigham v. Hanely, 17 Ill. 38; McClelland v. Snider, 18 Tl. 58.
> Fink v. Tatman, 36 Ind. 259.
; Dunn v. Johnson, 33 Ind. 54; Masterton v. The Mayor of Brooklyn’
7 Hill, 125; Storey v. N. Y. & Harlem R. R. Co., 6 N. Y. 85; Seaton v Secon
Municipality, 3 La. An. 44. Sedg. on dam. 63. This rule is just, for it
fixes such damages on the breach of the contract as the parties are pre-
sumed to have had in contemplation at the making of it as the probable
CONTRACTS FOR SERVICES. 499
that the measure of damages was the difference between the
value of the timber left unsawed and the profits which the
plaintiff would have received if the timber so left had have
been sawed.®
585. And where the defendant agreed to put into a steam-
boat certain machinery, within the time and of the quality
stipulated for, the court held that the plaintiff could recover
the ordinary hire of such boat for the period the contractor
was behind in getting in the machinery, and to which the
necessary costs of repair of the defective machinery put in, and
the use of the boat during the time occupied in making such
repairs, should be added."
586. Where the defendant, in consideration of one hun-
dred dollars, agreed to deliver to the plaintiff a patent machine
for sewing saddle trees as soon as such machine could be con-
veniently manufactured. The defendant failed to comply and
_tu furnish the machine according to contract. Suit to recover
damages for the breach.. The court held that the proper
measure of the plaintift’s recovery was the value of the use of
the machine during the time the plaintiff was deprived of the
use of it.!. In such cases the law aims to give the party in-
jured by a breach of contract, the value of that which the
other party stipulated to perform, but that value is to be com-
puted according to the ordinary and reasonable price.
And when the plaintiff employs the defendant for a stip-
ulated sum to support him for his natural life, and the defen-
dant fails entirely to comply, the plaintiff may at once
result of the breach of it. Dunn v. Johnson, supra. See Morrison v
Lovejoy, 6 Minn. 319; Fail v. McKee, 36 Ala. 61.
7 Brown v. Foster, §1 Pa. st. 165; Collins v. Baumgartener, Pa. st. 461
1 Davis v. Doe, 2 Ind. 599.
\
500 LAW OF DAMAGES.
commence suit for the breach, and the measure of damages
will be the value of the entire contract to the plaintiff at the
time of the breach, or a sufficient amount of money to support
him during life. And in case of such breach, the plaintiff
can recover for the future as well as the past.*” And where
there has been a partial performance and a breach and refusal
to further comply, the plaintiff may recover whatever the
contract is worth to-him; or where there has been a partial
failure, the plaintiff may recover an amount equal to what his
support has cost him during the time the defendant failed to
comply, or what would be sufficient to support him during the
time.!
* Schell v. Plume, 55 N. Y. 592; Gunther v. Pugsby, 12 Johns 126:
Shaffer v. Lee, 8 Barbour 412.
4 Blossom vy. Ball, 32 Ind. 115
CHAPTER XXXIV.
; BAILMENTS.
BartMen? Derinep. Dirrerent Drerers oF CARB. Depo-
siruM. ManpatumM. CommopatuM. Pienus. THE Dam-
AGES. Locario. Division or LocaTio. WAREHOUSEMEN,
WHARFINGERS. INN KEEPERS. CoMMON CARRIERS. LIVE
Stock. DAMAGES IN GENERAL. ‘
587. Bailment Defined. Bailment has been defined to be
the delivering of a thing in trust for some special object or
purpose, and upon a contract, expressed or implied, to conform
to the object or purpose of the trust’ “Asa rule the law allows
parties to make such contracts and agreements in reference to
their own property as they may see proper. And it is only in
the absence of such contracts that it fixes the amount of care
1 Story on Bailment, Sec. 2; Dowdson v. Graham, 2 Ohio st. 131; Bo-
hannan v. Springfield, 9 Ala. 789; Oakly v. The State, 40 Ala, 372; Fur-
‘low v. Gillan, 19 Texas 250.
502 LAW OF DAMAGES.
that the bailee must exercise in keeping the property intrust-:
ed to him, and his responsibility for loss or injury while it is
so in his possession.”
The responsibility of the bailee for loss will be measured
partially at least by the amount of benefits that are to result
to him from the bailment. For this care that he must exercise
will be increased or decreased in proportion to the considera-
tion or benefits that he is to receive from the bail.’
A learned commentator has laid down the rule as follows:
“Where the bailment is for the sole benefit of the bailor, the
law requires only slight diligence on the part of the bailee, and
of course, makes him answerable only for gross neglect. When
the bailment is for the sole benefit of the bailee, the law re-
quires great diligence on the part of the bailee, and makes him
responsible for slight neglect. But when the bailment is re-
ciprocally beneficial to both parties, the law requires ordinary
diligence on the part of the bailee, and makes him responsible
for ordinary neglect.”*
, It will be seen from what has already been said that the
liability of the bailee will depend upon the degree of care be-
stowed, or its correlative, the degree of negligence with which
he is chargeable. Law writers have classified the bailee’s du-
ties into “ordinary care,” “slight care” and “great care.” And
these may be defined as follows:
“Ordinary care” or diligence is that degree of diligence
and care which men of common prudence exercise in respect
Dwdson v. Graham, 2 Ohio st. 131.
3 Dart v. Love, 5 Ind. 181.
4 Dart v. Love, 5 Ind. 131; 4 Story on Bailment, Sec. 23.
BAILMENTS. 503
to their own concerns. The want of this would be ordinary
negligence.® 3
“Slight care” is that which is usually exercised by persons
under circumstances similar to those of particular cases, in
which the question arises, and where their own interests are
to be protected from a similar injury by men of common sense,
but below the average prudence of the community in which
they live, and the want of this would be gross negligence.°
5,
“Great care” is such as is exercised under such circum-
stances by men of unusual prudence, and the want of this
would be slight negligence.®
Sir William Jones divides Bailment up into five classes,
namely: :
588. 1. Depositum, or maker deposit without reward. In
this class of cases the obligation is that he will safely keep the
thing deposited with reasonable care, and that he will, upon
request, restore it to the depositor or otherwise deliver it ac-
cording to the original trust. He can only be held responsible
for bad faith or gross neglect if the deposit shouldbe lost or in-
jured while in his custody. The law requires the bailee to ex-
ercise a higher degree of care in the keeping of certain kinds
of property than in others. What would be reasonable care
5 2 Parson on Cont. 88.
* Field on the law of damages, sec. 900; Shear & Reed on Neg. 818,
19, 20; Story on Bailment, sec. 16, 17.
eS. & R. Neg. sec. 18; Brand v. Troy, etc, R. Co, 8 Barb.
368; Brown v. Lynn, 31 Pa. st. 512; Dreher v. Fitchburg, 22
Wis. 675; Johnson v. Hudson River Co., 20 N. Y. 65; 6 Duer
633; Tracy v. Wood, 3 Mason, 132; Doorman v. Jenks, 2 A. & E. 256;
Eldrige v. Adams, 54 Barb. 417; Parker v. Tiffany, 52 Ill. 286; Rose v.
Hill, 2 Man Gr. sec. 877.
504 LAW OF DAMAGES.
of a bag of wheat might be neglect if the bag contained
money. The nature of the property or deposit, its value, and
the danger of loss must be taken into consideration by the
court or jury in determining the question of gross negligence.
And if he delivers the property to one not authorized to re-
ceive it he would make himself responsible for its value, with-
out regard to the question of care or the degree of negligence he
has exercised.” Asa general rule the person with whom the
goods or property are deposited has no right to use them un-
less they are of such a kind that it is necessary to use in order
to take care of them. The bailee has no general or special
property in the thing bailed, but only in the right of posses-
sion, and if he disposes of the trust property the bailor may re-
cover its actual value.’ And when the bailor has made a de-
mand on the bailee for the trust property, and he refuses or ne-
glects to deliver it up, the bailor may bring an action for con-
version and recover damages as in an action in trover.* The
law not only requires the bailee to return the deposit, but the
increase or profits, such as young animals brought forth during
the time of the deposit, and interest on money where the trust
was made for that purpose, and for a failure to deliver either
on proper demand, give the bailor a cause for action.®
7fenkins v. Bacon, 111 Mass. 373; Hall v. Boston and Worcester R. R.
Co., 14 Allen 489; Lichtenhen y. Boston, etc., R. R Co., 11 Cush. 70;
Cass v. Boston & Lowell R. R. Co., 14 Allen 448-453; 2 Kent Com. (6th
ed.) 568; Hugh v London. etc, R. R. Co. L. R. 5 Ex. 51; Knowing v.
Manley, 49 N. Y. 192; Stewart v. Frazier, 5 Ala. 114; Ball v. Ling, 48
N. Y. 6.
5 Eldridge v. Adams, 54 Barb. 417; Parker v. Tiffin, 52 Ill. 286; Field
on the law of damages, 311; Chambers v. Shaw, 18 Peck 278.
‘Story on Bailments, Sec. 123; Burns v. Spoor, 22 La. An. 16; Hol-
brook v. Wright, 24 Wend. 169; Thorger v. Wright & Hutchins, 13 Vt.
504; Stephenson v. Price, 30 Texas 715; Parker v. Tiffin, 52 Ill. 286.
° Conkendale v. Eaton, 55 Barb. 188; 3 Home Practice; Bornler v.
Neye, 10 Cush. 416; Parker v. Tiffiny, 52 Ill. 286; Railway Co. v. Sulli-
van, 14 Georgia 283. A mere depositary is not liable until a refusal to
deliver upon demand. West v. Murphy, 3 Hill (8. C.) 284; Hill vy. Wig-
\
BAILMENTS. 505
589. Mandatum or commission which is gratuitous and
by which the mandatary undertakes to do something about
the thing bailed. This is where the bailee undertakes to do
some act for another in respect to the trust property. If the
bailee fails to do the act, the bailor has no right of action .
against him, for the contract is without consideration, and
void. Although the bailee is not bound to do the act, yet if
he proceeds to do it he will be held responsible for any injury
arising from gross negligence in its performance. Thus, where
the defendant undertook, gratis, to carry several hogsheads of
brandy from one cellar and deposit ‘them in another, and he
did it so negligently and carelessly that one of the hogsheads
was staved and the brandy lost, it was held that the defendant,
not having uscd ordinary care, was liable for the loss. The
bailee will be held lable for all injuries to the tryst property
arising from an omission of that care which a bailee without
hire or manditaries of ordinary prudence usually takes of
property of the nature of that in question. The test is not
whether he has omitted that care which very prudent persons
usually take of their own property, for the omission of that
would be but slight negligence; nor whether he has omitted
the care that prudent persons ordinarily take of their own
property, for that would be but ordinary negligence; but
whether there be a want of that care which men of common
sense, however inattentive, usually take, or ought to be pre-
sumed to take of their property, for that is gross negligence.
But a bailee is sometimes held responsible for negligence for
misfeasance when he would not be for non-feasance.’ And as
a rule, where one voluntarily proffers to perform some act for
gins, 31 N. H 292; Brown v. Cook, 9 Johnson (N. Y. 361; Phelps v.
Boswick, 22 Barb. 314; Duncan v. Moggett, 25 Texas 245; Nelson v.
King, Id. 655; Jackman v. Patridge, 21 Vt. 588.
6 Twey v. Wood, 3 Mass. 132; 1 U.S Circuit 1822, 5 McLean 218.
12 Kent Com. 569.
506 LAW OF DAMAGES.
another in relation to the thing bailed, in which great care and
skill is required of the bailee, than where the request comes
from the bailor.’ For measure of damages see depositum.
590. Commodatum or Loan for Use Without Pay, where the thing
is to be Returned in species. The borrower of property of any kind
is generally bound, not only to use ordinary, but the greatest
care to preserve the thing borrowed, and must return it to the
bailor in as good condition as it was when he obtained it, sub-
ject to the ordinary wear and tear from reasonable use. And
he will be held responsible for injury arising from slight neg-
ligence on his part, but not for loss by the act of God, by rob-
bery, theft or by an irresistable force, or any other cause over
which he had no control.’
591. The Damages. The actual loss is the measure of dam-
ages. The bailee is held responsible for all ordinary expenses,
2 Kent Com. 571: ‘And when the profession or situation of the gratu-
itous bailee is such as to require skill, he is liable for all damages caused
by his neglect to use it.” Wilson v. Brett, 11 Mees & W. 113; Redfield
on Bail, Sec. 600. A manditary is answerable for gross negligence only,
Kemp v. Falow, 5 Ind. 462; McNabb v. Lockhart, 18 Ga. 495; Connor
v. Weston, 8 Ind 315; Jourdon v. Reed, 1 Iowa 135; Storer v. Gowen,
18 Me. 174; Lamply v. Scott, 24 Miss. 528; McClane v Rutherford, 8
Mo. 109; Stand v. Bell, 2 Hawk (N C) 145; Sodowiski v. McFarland,
3 Dana (Ky.) 205; Tracy v. Wood, 3 Mas. 132; Thompkins v. Saltmarsh,
14 Sedg. & R (Pa.) 275; Bland v. Normuck, 2 Murph. (N.C.) 318;
Beardslee v. Richardson, 11 Wend. 25; Anderson v. Foresman, Wright
(Ohio) 598.
3 Suit for the value of a horse. Answer; That the horse was bor-
rowed to goto a certain place and return, and that while the defendant
was on the way, and without any fault or negligence on his part he was
met by some cavalry soldiers of the United States, who forcibly took
said horse from him. Held answer good. Watkins v. Roberts. 28 Ind.
167; see also Coggs v. Bernard, 2 La. Raymond, 909; Jones on Bailment,
68; Edwards on Bailment, 167; Wood v. McClue, 7 Ind. 155; Scranton
v. Baxter, 4 Sandf. N. Y. 5; Martin v. Culberson, 64 N. C. 328; Field on
dam, 313. ‘
BAILMENTS. 507
but not for extraordinary ones, or such as arise from the inher-
ent infirmity of the property, or are required for its preserva-
tion without any neglect on the part of the borrower, the
lender must bear them. And where the bailee is compelled to
pay extraordinary expense, he has a lien on the property for
its payment. But in order to escape extraordinary expense,
the bailee must not depart from the terms of the bailment ;, for
if there is a departure from the terms of the bailment, as
where a horse is hired to go to Newport and is taken by the
bailee to Jamestown, ten miles in another direction, and the
horse dies froin some disease, the bailee, as a general rule, will
be liable for the value of the horse.*
592. Pignus, a pawn or pledge, as, where a thing is bailed
to a creditor as security for a debt or engagement.' The
pawnee is bound only to take ordinary care of the goods, and
is only answerable for ordinary neglect; and is only held re-
sponsible for an omission of that care that men of common
prudeuce take of their own affairs. And he may ordinarily
use the property, but if it is of such a nature as to be injured
by use, such as clothes, etc., he cannot use them. If the
pawn be of such a nature as to be an expense upon the
pawnee, he may use the pawn ina reasonable manner. If the
property is lost through the want of ordinary care,, the meas-
ure of damages would be its value, or in case of conversion,
3 Martin v. Culberson, 64 N. C. 328; Field on dam. 313.
1 Delivery or transfer of custody is absolutely essential to constitute a
pawn. First Nat’l Bank v. Nelson, 38 Ga. 391; Nevon v. Rupe, 8 Ia.
207; Foltier v. Schroder, 19 La. Ann 17;' Beeman v. Lawton, 37 Me.
543: Walcott v. Ruth, 22 N. H. 196; Propst v. Roseman, 4 Jones (N. C.)
L. 180; Thompson v. Andrews, 8 N. C. 453 The difference between a
pledge and a mortgage is that in case of a pledge the title remains in the
pledgor, and in case of a mortgage it passes to the mortgagee, sub?ect to
be diverted. Sims v. Canfield, 2 Ala. 555; Eastman v. Amy, 23 Me. 248;
Ward v. Sumner, 5 Pick. 60; Haver v. Love, 2 N. H. 13.
508 LAW OF DAMAGES.
damages for conversion, And when the pawnee sells the
property he can retain a sufficient amount of the money to
satisfy his claim against the pawnor, and must pay the re-
mainder over tohim. In case the property is lost by theft,
if it was owing to the negligence of the bailee, he will be
responsible therefor; if not, the loss falls on the pawnor.*
593. The Damages. As we have already said, if the prop-
erty is lost by the omission of- ordinary care, the measure of
damages would be its value. And in case it is injured under
like circumstances, the actual loss sustained would be the
damages; and in case of a sale to satisfy the debt, if, after the
debt is paid there is a remainder, the pledgor may, after de-
mand and refusal, recover that amount from the pledgee, less
the necessary expense incurred by the pledgee in taking care
of the pledged property and in making sale of it. The pledgor
is entitled to any increase and income of the pawn, unléss
there was a different contract. And in case of conversion the
measure of damages is the highest market price of the prop-
erty between the time of the conversion and trial.’
594. The Pledgee’s Right of Action and Damages. The pledgee
has only a temporary interest in the property, therefore in an
‘2 Parsons on Contract, 86; Field on law of dam, 314; Petty v. Over-
all, 42 Ala. 145; Edwards on Bailment, 223; Story on Bailments, sec. 238.
The pledgee may, after the debt becomes due, sell the pledge without
resorting to judicial proces, but in such cases, unless there is an ex-
pressed waver in the contract between the pledgor and pledgee,the latter
must give the former notice. Parker v. Braneker, 22 Pick. 40; Wash v.
Pond, 2 Allen 744; Wheeler v Aubold, 5 Duer NX. Y. 325.
2 Parsons on Contracts, 86; et. seq. Petty v Overall, 42 Ala 145; Ed-
wards on Bailments, 223; Story on Bailments, sec. 238; Markham v.
Joudon, 41 N. Y. 235; Rozt v. McClelland, 48 Ill. 345. Where the
pledgor has paid the debt which was secured by the pledge, the pledge
must account for all income, profits and advantages derived by him from
the bailment. Humaker v. Sturgis, 29 Cal. 142; Brown v. Runnolt, 14
N, H. 693; Elliott v. Armstrong, 2 Black 198.
7 See authorities above.
BAILMENTS. 509
action by him against one who has purchased it of the pledgor
he can recover only the amount of his claim; but in an action
against a third party, who has taken the pledge from him, he
may recover its full value. Thus: When an action was
brought by a pledgor against a sheriff for a conversion of goods
-pledged, the sheriff, who had seized them under a lawful writ
in his hands, will be treated as a privy with the owner, the
pledgor, provided he has pursued the law in making such.
seizure, and will be held liable only for the plaintiff’s special
inetest in the goods; but in any other event he will be treated
as a stranger, and held for their value.’
And it is now well settled that a pledgor may transfer the
pledged property to another, subject to the pledge, and the
purchaser will take all the rights and interest in the property
that his grantor had, and may, on tendering the amount that
is secured by the pledge on demand maintain an action there-
for, or for its value, and the measure of damages will be the
same as in other conversions.’
s
‘
595. Locatio, or Hireing for Reward. Chancelor Kent says:
“This isa contract by which the use of the thing, or labor,
or service about it, on stipulation to be given for a reasonable
consideration.”* The contract of hireing being one of mutual
benefit, the hirer is bound only for ordinary diligence, and is
responsible only for ordinary negligence or the omission of tat
degree of care and diligence which the generality of mankind
use in keeping their own goods of the same kind* There is
‘ /
1 Bromwell v Hankins, + Barb. 491; Spoor v. Holland, 8 Wend. 445.
2 Treadwell v. Davis, 34 Cal. 601.
Franklin v. Neal, 13 M. & W. 481. Whena pledgee has sold the
pledge without a right to do so, it will be treated as a conversion. *Cor-
titue v. Laesing, 2 Cai (N. Y.) 200; Dykers v. Allen, 7 Hill 497; Wilson
v. Little, 2. N. Y. 448; Lewis v. Graham, 4 Abbs. Pr. 106; Hutton v. Ar-
nett, 51 Ill. 198; Thayer v. Dante, 104 Mass. 254.
Jt
510 LAW OF DAMAGES.
on the part of the hirer an implied obligation, not only to use
the thing hired with due care and moderation, but also not to
apply it to any other use or detain it beyond the time for
which it was hired. Bnd if the thing bailed is used in a
different manner, or for a different purpose, or for a longer time
than was agreed upon by the parties; the hirer is answerable
for all damages and even for loss which due care could not have
prevented.®
The hirer must restore the property in as good condition
as when he received it, subject of course to the wear and tear
from usage. And in case he fails to do so, and the bailor
brings an action for conversion, the measure of damages will
be the value of the property, together with the stipulated hire
for the time agreed upon and interest on th whole amount.’
596. The Division of the Class Locatio. The class Locatio, or
hireing for reward, is subdivided into: 1. Locatio rei, a hire-
42 Kent Com 585-586.
5 Mayor of Col. v. Howard, 6 Ga. 213.
* Lewis v. McAffee, 32 Ga. 465; Wheelock v. Wheelwright, 5 Mass.
104: Homer v. Swing, 3 Pickering 492; Rotch v. Howes, 12 Mass. 136;
Sheck v. Strong, 4 N. J. L. 87; McNeills v. Brooks, 1 Yerg. 75; Mayor of
Cols. v. Howard, 6 Ga. 213; Bamfield v. Whipple, 10 Allen (Mass.) 27;
DeTollemer v. Fuller, 1 Treaden (S. C ) const. 121,
Where a bailee for hire returns the hired property in a damaged con-
dition, and fails or refuses at the time, or subsequent. to give any account
of how the injury occurred, the law will presume negligence on his part
and the burden will be upon him to show amount of negligence. Logan
v. Matthias, 6 Pa st. 417.
7 Nurgus v. Simpson, 99 Mass. 388; Duncan v. R. R. Co, 2 Rich. 613;
Mayor of Col. v. Howa, 6 Ga. 213; Fisher v Kyle, 27 Mich. 454; Field
v. Brockett, 56 Me.121; Buford v. Tucker, 44 Ala. 89; Camberlain v.
Cobb, 32 Iowa 161. Actual delivery by the bailee on demand of the true
ownér, who has the right to immediate possession of the goods bailed,
is a sufficient defense of the bailee rgainst the claim of the bailor, an |
there is do difference in this regard between common carriers ahd other
bailees. The Idaho, 93 U.S. 575.
BAILMENTS. 511
ing by which the hirer gains a temporary use,of the thing. 2.
Locatio operis fouindi, where something is to be done to the
thing delivered; and locatio operis mecium vehendrum, where
the thing is merely to be carried or transported from one place
to another.
The class of cases where the bailee is to bestow care or
labor embraces: 1. Where mechanics or manufacturers are
employed to manufacture or repair the article. 2. Where
peoperty is delivered toa warehouse. 38. Where it is delivered
by a guest to an innkeeper.
The mechanic to whom material is delivered that work
may be performed thereon must use ordinary care and dili-
gence to preserve the property intrusted to him and in case he
neglect to do so he will be responsible for whatever injury the
property may sustain by reason of his want of such care. But
he is not liable for mere accidents, although in case of loss he
must show that the loss occurred without fault on his part.”
597. Warchousemen and Wharfingers. Warehousemen and
wharfingers are not, like common carriers, held responsible for
all losses, except such as arise from the act of God or public
enemies, but are only responsible for loss happening through
a failure to exercise reasonable and ordinary care and diligence.
And if the goods delivered to them are injured through the
want of this care, they will be held responsible to the bailor
for such damages as may be sustained. And where the bailor
makes a demand for the goods, and the bailee refuses to give
79 Car. & P. 632; McCain v. Kimbell, 4 McCord (8. C.) 220; Foster v.
Taytor, 2 Brem. (8. C. 348; Chambers v. Crawford, Add (Pa.) 151; Cox
v. Reynolds, 7 Ind. 257. The some liability attaches to a commission
merchant if he has not used proper diligence before a fire to sell the
goods. Francis v. Castleman, 4 Bibb. Ky. 282.
512 LAW OF DAMAGES.
them up, he may bring an action for conversion and recover
the same damages as in an action of trover.* A sale by a
warehouseman or wharfinger of property deposited with him
for storage, without notice to the owner, is a conversion of the
property.’
The bailee holds a lien on the property for storage; and he
tay, on reasonable notice sell all, or as much of the property
as will satisfy his Hen. The bailee may maintain an action
for the recovery of the property, or for any injury thereto,
against a third party, and will-be held responsible for its value
if he delivers it by mistake to the wrong party.? And in case
of the loss of the property the bailor will not necessarily be
confined in his-recovery to the cost of the goods, or price for
which they were sold, but the market value may be recovered‘
As the bailee is only a trustee holding the goods for the bailor,
they are subject to execution, and if they are taken from him
by authority of law, it is a good defense in an action by the
bailor for their value.’
598. Inn Keepers. The policy of the law has devolved
upon the inn keepers a severe liability, lest they may be
tempted by motives of gain to collude with evil disposed per-
sons and afford facility in purloining the property of their
‘Story on Bailment, p. $51; Cox v O'Riley, 4 Ind 368; Williard v
Bridge, 4 Barb. 361; C.&C. Air L RR Co. +. MeCool, 26 Ind. 140; Ban
smer v. 1 W R. R Oo., 25 Ind. 434; Chase et al v. Washburn, 1 Ohio
st. 244, Rapp v. Grayson, 2 Black 130; Harper v. Bound, 10 Ind. 32;
Pribble v. Kent, 10 Ind. 325.
’ Pribble v. Kent, 10 Ind 325; Stevens v. Law, 2 Hill 132.
+ Jordan v. Sherman, 28 Ind. 136.
' Pribble v. Kent, 10 Ind. 325; Evans y. Dartington, 5 Black, 321.
* Williard v. Bridge, 4 Barb. 361.
* Leonard v. Dunton, 51 III. 482.
* Burton y. Wilkinson, 18 Vt. 180.
BAILMENTS. 513
guests; and they are held, like common carriers, to be the in-
surers of the property entrusted to their care by guests, except
against loss by the acts of God, public enemies, neglect or
fraud of the bailor.’. And where goods are lost or injured, the
inn keeper will be responsible for the damage occasioned by
his neglect; and the bailor will not be limited in his recovery
to the cost of the goods. The question of contributory negli-
gence arises in this class of cases (see Negligence).
599. Common Carriers. A common carrier is a person who
carries goods of others for hire ; one who undertakes for hire to
carry for any who chooses to employ him. They are of two
kinds, by land as the owner of stages, stage wagons, railroad cars,
teamsters, cartmen, draymen and porters; and by water, as
owners of ships, steamboats, barges, ferrymen, lightmen and
canal boats. The term common, as applied to carrying, means
one who is engaged in the business of hiring to carry for any
and all who may choose to employ him.. A common carrier is
an insurer against all damages to, or loss of goods entrusted to
his care for transportation, except such as may arise by the
act of God, enemies of the country, or the acts of the owner
himself. But if there is some hidden defect in the property,
or in the packing, and damages result from that cause, it will
be considered the act of the owner, and the carrier will not be
liable therefor... The act of God denotes natural accidents,
72 Parson on Contract, 146; 3 Nunoles v. Howe, 1 E. D.S. N. Y. 54.
Inn keepers, as well as common carriers, are regarded as insurers of the
goods of their guests while in their keeping, and are bound to make res-
titution for any injury or loss not occasioned by the act of God, common
enemy, or by neglect or fault of the guests. 2 Dana Abt. 51; 8 Co. R.
32; 5 T. R. 273; 33 D.yer 266; 8B. & C.9; 1 Yeates 34; 21 Wend. 282;
2 Kent Com. 594; Thickstun v. Koward, 8 Black, 535; 49 Ind. 28; Laird
v Eichold, 10 Ind. 212; Huntington v. Drake, 24 Ind. 347.
1Klauber v. Am. Exp.,Co., 21 Wis 21; Angles on carriers, sec. 214;
Clark v. Rochester Co., 14 N. Y. 570; Bissel v. N. Y. Cent. R. R. Co., 25
N. Y. 442; Smith v. New Haven R. Co., 12 Allen 531; Mich. Cent. R. Co.
514 LAW OF DAMAGES.
such as lighting, earthquakes, tempest and all other unavoid-
able or inevitable aceidents, or that which operates without
the aid or interference of man.’
600. Exception to the General Rule in Case of Live Stock, A
common carrier does not undertake, unless by expressed agree-
ment, to become the insurer of live stock entrusted to him for
transportation from one place to another; he will not be held
liable for such injuries as arise only from their naturé and
propensity, and which could not be prevented by foresight,
vigilance and care ;* nor will he be held, in the absence of neg-
ligence, liable for such injuries as occur in consequence of the
vitality of the freight.*
601. When the Common Carrier’s Liability Commences and Ter-
minates. The common carrier’s liability as insurer of the goods
commences as soon as he receives them for transportation.'
But it is sometimes quite difficult to fix the exact time when
his obligation as such insurer ceases. But it may be laid down
v. McDough, 24 Mich. 165; Boyce v. Anderson, 2 Peters 150; Walpole v.
Bridges, 5 Black 222; Cincinnati & Louisville Mail Line Co. v. Boal etal,
15 Ind. 345; United States Exp. Co. v. Rush, 24 Ind. 403; St. Louis &
Sousheast. R. R. Co. v. Smock, 49 Ind. 302; 49 Ind. 596; Am. Exp. Co.
v. Smith, 33 Ohio st. 511.
» Walpole v. Bridges, 5 Black 222; Jones on Bailments, 106; Story on
Bailments, 318-319; 2 Kent’s Com. 609; 10 Johns Rep. 1; Leighs N. P.
508-509; Roll Ab. P., 4 Co. let. 89; Strohan v. Detroit, 23 Wis. 126; Field
on dam. sec. 369.
* Evans v. Fitchburg R. Co., 111 Mass. 142; Louisville, Cincinnati &
Lex. R. R. Co. v. Hedges, 9 Bush 645; Mich. South. & N. E. Ind. R. R.
Co. v. McDonough, 21 Mich. 165; McManus v. Yorkshire, etc., Co., 4H.
& N. 327; Car v. Lancashire, etc., Co:, 7 Exch. 707; McManus v. Lan-
cashire, etc., 2 H. & N. 6938; Johnson v. Midland Co. 4 Exch. 367; 2 Red-"
field on Railways, 116, 117, 118; Clark v. Rochester R.R Co.,14N Y.
570; Bissel v. N. Y. Cent. R. R. Co., 25 N. Y. 442; Smith v. New Haven
R. Co., 25 N, Y. 442; Boyce v. Anderson, 2 Peters (U. 8S.) 150; Hall v.
Denfro, 3 Met. 51.
Myers v. Limche, 31 Ind. 208,
BAILMENTS. 515
as a general rule that the carrier upon the arrival of the gaods
at their place of destination, must prepare them in a fit con-
dition and place for delivery, and give the consignee notice
that they have arrived and are ready for delivery, and he will
be held responsible for the safety’ of the goods until a reasona-
ble time has elapsed for the consignee to examine and remove
them; and the carrier is liable as such in the mean time,
while the goods are waiting for delivery.’
602. Thus it was held that the liability of a common car-
rier is usually regulated by contract, but in the absence of ex-
pressed agreement, the usage and custom will have much'to do
with settling such question.’ A party who contracts with a
common carrier for the transportation of his goods is presumed
to k.ow and be familiar with the carrier’s means and methods of
transportation and to contract with him with an understanding
2 Adams Exp. Co. v. Daniel, 31 Ind. 20; Marshall v. Am. Exp. Co., 7
Wis. 1; Both v. Buffalo, etc. R R. Co., 34 N. Y. 548; Richards v. God-
‘dard, 23 Howe U.S. 28; Young v. Smith, 3 Dana 91; Russell Manf. Co,
v. N. H. St. Bt Co., 50 N. Y. 125; Boarne v. Gatlif, 11 Cl. & F. 49; Allen
Burt, 20 Wend. 206; Fenner v. Buff. & St. Line R. R. Co., 44 N. Y.510; ©
Parket v. Mel. & St. R. R., 32 N. H. 692; Moses v. Boston & Maine R. R.
Co., 32 N. H. 539-540; Morris & Essex R. R. Co. v. Ayers, 5 Duct 394;
Blumenthal v. Branard, 38 Vt. 413; Jeffersonville R. R. Co. v. Cleveland,
2 Bush 473-475; Dean v. Vaccaro & Co., 2 Head 490-492; The Petona, 2
Curtis C. C. 21; Ala. & Tenn. R. k. Co. v. Kidd. 35 Ala. 218; Barcla v.
Clyde, 2°E. D. Smith 97; Gaines v. The Union Trans. and Ins. Co., 28
Ohio st. 418; Graves v. H. N. Y. Steamb. Co, 38 Com. 143; Redmond v.
The Lon., N. Y. & Phil Steamb. Co., 46 N. Y. 578; Mobile & G. R. Co. v.
Prewitt, 46 Ala. 63; Shenk v. Phil. Steamb. Co., 60 Pa. st. 109; Red-
mond v. Livepool & Co.. 42 Pa. st. 109; McMaster v. Penn. R. R. Co., 60
Pa. st. 397. The authorities are much in conflict on this point. There
are many authorities that hold that the carrier’s responsibility ceases as
soon as the goods are removed from the vessel or cars to the wharf or
platform, or into a freight house. Norway Pl. Mill Co. v. Boston Manf.
Co., 1 Gray 263; Lemon v. Western R. R. Co. 16 Grag. 132; Rice v. Bos-
ton & Worcester R. R. Co.,98 Mass. 212; Shepherd v. Easter R. R., 3
Ex. 189
2 The Pitts. & St. L. R. R. Co. v. Nash et al, 43 Ind. 423; Redfield on
‘Railways, sec. 2, p. 41; 43 Ind. 123.
4
516 LAW OF DAMAGES.
that his goods are to be conveyed to their place of destination
by the ordinary means used by the carrier for that purpose.
If, therefore, goods are delivered by a consignor to the agent of
a railway company, the presumption will be that they are to
be carried by the cars on the track of the company. Asa gen-
eral rule common carriers by wagons are required to deliver
the goods to the consignee at his house or place of business,
and their liability as common carriers continues until such
delivery is made, put the rule is not applicable to common car-
riers by vessels on the seas, lakes, or navigable rivers, nor to
common carriers by railroads. Vessels are necessarily confined
to the water, and discharge their cargoes on the wharves at
public landings, and in such cases, general custom, arising
from necessity and the conveniences of commerce, sanctions
such discharge at the proper place of delivery. And if the
consignee is not present to receive the goods, thé carrier may
discharge himself from further liability by notifying the con-
signee of their arrival and allowing reasonable time for him
fo prepare to take them away, or if the consignee cannot be
found, by having them stored in a proper warehouse for
him. Carson a railroad are necessarily confined to the-track
of the road and unless the consignee should have a warehouse
immediately by the track, an actual delivery cannot be made
without change in the means of transit. From the very na-
ture of the mode of carriage, the convenience of the company,
if not an absolute necessity, demands that the depots or ware-
houses should be erected at places where goods are received
and discharged, in which they may be safely stored, and there
should also be agents at such places for the transaction of nec-
essary business. These warehouses constitute the proper place
of delivery. The consignee must be presumed to know that
the goods are there discharged; and that it is his duty to re-
ceive them at that place. When the goods have reached their
destination the transit is at an end, and when they are dis-
charged from the cars, and in the absence of the consignee or
BAILMENTS. ° 517
his agent to receive them, are safely stored in a warehouse, the
liability of the company is then terminated without notice to
the consignee of their arrival.” Whenever the goods intrust-
ed to a common carrier by water or railare properly stored in a
safe warehouse, the transit is at an end, and their liability as
common carriers ceases, and they assume the responsibility of
warehouse keepers.’
603. But this rule only applies in the shipment of mer-
chandise, and is never applied on the shipment of heavy arti-
cles, such as lumber, coal, timber, etc. A delivery of such
commodities is considered complete when the cars arrive at
their destination and on the track at the place where such
freight is generally unloaded.6 But when carriers by water,
or a railroad company, has made a special contract to deliver
freight beyond its lines, or in a different manner, its contract
will be binding, and it will be held responsible for damages for
failure to comply with such agreement.’ It may be considered
as a settled rule that where a common carrier, by steamboat
or other vessels, in the due and common course of his business
delivers the goods entrusted to his caré, into the hands of the
wharfinger, at their place of destination, the transit is at an
end and his responsibility as a carrier terminates, unless he
“has expressly contracted to do something more.’
604. The Right of the Carrier to Limit His Inability. There
has been much controversy recently among members of the
5 Bansemer et al v. The Toledo & Wabash R’y Co., 25 Ind. 434, The
Norway Pl. Co. v. Bost. & Maine R. R. Co., 1 Gray 263; Hyde v. T. & M,
N. Co., 5 T. R. 397; Thomas v. Bost. & Prov. R. R. Co., 10 Metcalf 472;
Denny v. N.Y. Cent. R’y Co., 13 Gray 48I; Richards v. Mich. South. R
R. Co., 20 Ill. 404. 2
® The Pittsburg, Cincinnati & St. Louis R’y Oo. v. Nash et al, 43 Ind.
; 423; Redfield on Rail. sec. 2, p. 61.
7™ Mon. Oil Co. v. Cander & R. R. Co., 32 Barb. N. Y. 72.
7 Farmers’, etc., Bank v. Chapland T. Co., 23 Vt. 186.
Be ; LAW OF DAMAGES.
legal profession in regard to the right of common carriers to”
limit their common law liabilities by special contract. But it
may be considered as settled’that they have the power to limit
such liability by special contract for all damages except those
which arise from their own negligence.’ But it is sometimes
quite difficult to tell whether there has been a special contract
between the parties or not. If the consignor, when he deliv-
ers the goods to the carrier takes a receipt for the goods, and
that receipt contains provisions limiting the common law
liability of the carrier, and the consignor accepts the. receipt
with a full knowledge of its terms, and intending to assent to
the restrictions contained in it, it becomes his contract as fully
as if he had signed it. But the simple delivery of the receipt
to the consignor is not conclusive upon him. Whether he had
a knowledge at the time of the terms of the receipt, and
assented to its restrictions, is for the jury trying the case to
determine from the.evidence.’
605. Damages where Common Carriers Refuse to Carry Goods.
Where a person or corporation has assumed the charter of a
common carrier, either by expressly offering his services to all
4 Merch. Dis. Trans. Co. v. Bolles, 80 Ill. 478; Wiggins v. Boston R. R,
Co., 120, Mass. 201.
5Rice v. Kans Pac. R’y, 63 Mo. 314; Gaines v. Un. Trans. etc. Co., 28
Ohio st. 418.
* Field v. Chicago, etc. R. R. Co., 71 Tll. 458, 42 Ill. 89; 54 Ill. 89; 60
Ill. 421; Schiff v. New York, etc.,52 Howe (N. Y.) Pr. 91; Gaines v.
Un. Trans etc, Co., 28 Ohio 418.
But where goods are taken under a verbal contract for their transporta-
tion, such agreement is not altered by a bill of lading, partly written and
partly printed, delivered to the shipper after he had parted with the con-
trol of his gouds, notwithstanding such bill of lading, by its terms, limited
the liability-of the carrier and expressed on its face that by accepting
the receipt would be to agree to its terms. The mere receipt of the bill
after the verbal agreement had been acted upon will not exclue the con-
signor from showing what the agreement was under which the goods
were shipped. Schiff v. N. Y. etc. R. R. Co., 52 Howe N, Y. Pr. 91.
BAILMENTS. 519
who will hire him, or by so conducting his business as to lead
the public to believe that he is acting in that capacity, the
law, in the absence of an express agreement, will fix his
responsibilities. But in order to impress upon him the liabil-
ity of a common carrier, his conduct or proposition must
amount to a public offer to carry for all who tender him such
goods as he is accustomed to carry. When this is the case,
then those who tender him the goods to carry accept his offer
and he becomes bound to carry them ; and if he refuses to do
so, having convenience and being tendered satisfaction for the
carriage, he is liable to an action if he refuses to-accept the
goods and to transmit them to the place proposed.* And in an
action for damages for such refusal, the measure of the plain-
tiff’s recovery will be the difference in the value of the article
where it is tendered for transportation and its value at its pro-
posed destination, less the freight for carriage.’ But to this
general rule there is an exception.. The law, for wise reasons,
‘imposes upon a party subject to injury from a breach of con-
tract the active duty of making a reasonable exertion to render
the injury as light as possible, and if he, through negligence
or wilfullness, allows his damages to be unnecessarily enhanced,
the increased loss falls upon him. Therefore if the plaintiff,
after the carrier had refused to receive and transport his goods
could, without delay, have procured other transportation by a
reasonable exertion, the damages would only be the difference
between the regular price and that paid for the transportation.®
606. The General Rule of Damages. The measure of dam-
age in case of a loss of all, or any part of the goods, by a com-
mon carrier, which he undertook to deliver, is the value of the
goods at the time and place where they should have been de-
4 Jackson v. Rodger, 2 Shaw 327; Rily v. Howe, 6 Bing. 217; 1 La. 646;
2 Kent 598; Varble v. Bigley, 9 Cent. La. Jour. p 153.
° Ogden y. Marshall, 8 N. Y. 340; Bracket v. McNair, 4 Johns 170.
520 LAW OF DAMAGES.
livered, with interest, less the proper charges for transporta-
tion.’ In this class of cases,as in all others, the law aims to
compensate the plaintiff for actual loss arising from the natural
and proximate consequence of the defendant’s act, and excludes
speculative profits and remote and indirect losses.’
But where goods have been delivered to the plaintiff in a
damaged condition, and he sues for the injury, he can recover
the dimunition in the price of the goods where they were at
the time of the injury.* And where a common carrier, with-
out a legal excuse, refuses to carry goods for the plaintiff, the
measure of damages is the difference between the value of the
goods at the point of destination when they should have ar-
rived there, and the place of detention, including necessary
expense for such detention, deducting reasonable charges for
transportation.’ In case of a delay in the transportation of
merchandise beyond the time of the agreement, or where there
is no specified time for their delivery beyond a reasonable time,
the damages will be the difference in the value of the property
at the time when, and place where, it should have been deliv-
ered, and its value when it was delivered; and from this
amount freight should be deducted if it has not been paid.
? Mich. South. & Nor. Ind. R. R. Co. v. Caster, 13 Ind. 164; Sturgess v.
Bissel, 46 N. Y. 462; Sherman v. Wells, 28 Barb 403; Spring v. Haskill,
4 Allen 112; McGregor v. Killgore, 6 Ohio 358; Tourent v. Vaughn, 30
Vt. 90; Taylor v. Collier, 26 Ga 122; Dawes v. N. Y. Cent. R. Co., 1 Hill
543; Perkins v Portl. R. R. Co., 47 Me. 573; Rugles v. Howers,1 Cal.
108-203; Watkins v. Loughton, 8 Johns 213; Edmonson v. Baxter, 4
Hayne N. C. 114.
? Meding v. N. Y° etc. R. R. Co., 36 Barb. 534; Rice v. Ontario Steam-
boat Co., 56 Barber 384; Cooper v. Young, 22 Ga 269.
* Rodgers et alv West et al, 9 Ind. 400; Pendal v. Rench, 4 McClane
325; Young v. Poe U.S, 1 Cal. 388; 47 N. Y. 29; 14 Mich. 489; 13 How.
U.S. 307; 20 Wis. 594; 46 Miss, 459; Sedg. on Meas. Dam. 423,
5 Galena R. R. Co. v. Roe, 18 Ill. 488; 8. P. O’Connor v. Garber, 10
Watts 418; Mich. Railroad Co. v. Carter, 13 Ind. 164.
4 Sisson v. Cleav, etc. Railroad Co., 14 Mich. 489; Peet v. Chicago &N.
BAILMENTS. 521
607. But under certain circumstances the common car-
rier will be subject to larger damages. Thus where he receives
an article of merchandise and is notified that it is sent for a
particular purpose, and he fails to deliver the same according
to the agreement, or, if there is no stipulation, within a reason-
able time and the plaintiff is injured, and if the damages are
such that he might have reasonably conemplated at the time
of receiving the property would have occurred from the delay
he will be responsible for the loss.*
\
In the case of Hadley v. Baxendale, the plaintiff, who was
the owner of a flour mill, sent a broken iron shaft to an office
of the defendants, who were common carriers, to be conveyed
by them to Greenwich to a party who had a contract with the
plaintiff to make hima new shaft. But before they could
make the new shaft it was necessary that the broken shaft
should be forwarded to Greenwich so that the new shaft might
be made to fill the exact place of the old one. The defendants
were to deliver the shaft at Greenwich the second day after its
receipt by them, but failed to deliver according to contract.
The defendants, at the time they received the shaft for trans-
portation, were notified that the plaintiff’s mill was stopped,
and that the shaft must bedelivered immediately at Greenwich.
Suit fordamages for the loss of profits by reason of the mill
standing idle. The Court, in commenting on the question of
damages, said: “Now, we think the proper rule in such cases
W. Railroad Co., 20 Wis. 594; Weston v. Grand T. R. Co., 54 Me. 376;
Kent v. Hudson R. Railroad Co., 22 Barb. 278; Boggs v. N. Y. C. Railroad
Co., 28 Barb. 515; Rowe v steamer City of Dublin, 1 Ben. 46; Smith v.
Griffith, 3 Hill 333; Wilson v. Lancashire etc. R. Co., 30 L. J. C.P. (N.
S.) 232; Inglethem v. North. R. Co., 7 Gray 86; Cutting v. G. R. Railroad
Co., 13 Allen 381; Scott v. Boston & N. W. Steamship Co., 106 Mass, 468.
* King v. Woodbridge, 84 Vt., 565; Deming v. Grand Trunk R. Co , 48
N, H., 455; Whalon v. Aldrich, 8 Mich., 346; Cooper v. Young, 22 Ga.,
269; 4 Field on law of dam., 323-4.
522 LAW OF DAMAGES.
as the present is this: where two parties have made a contract
which one of them has broken, the damages which the other
party ought to receive in respect to such breach of the contract
-should be such as may fairly and reasonably be considered
either as arising naturally in accordance with the usual course
of things from such breach of contract itself, or such as may be
reasonably supposed to have been in contemplation by both
parties at the time they made the contract as the probable re-
sult of the breach of it. Now, if the special circumstances un-
der which the contract was actually made were communicated
by the plaintiff tothe defendant, and thus known to both par-
ties, the damages resulting from the breach of such contract
which they would reasonably contemplate would be the
amountof injury which would ordinarily follow from the
breach of contract under these special circumstances so known
and communicated. But on the other hand, if these special
circumstances were wholly unknown to the party breaking the
contract, he, at the most, could only be supposed to have had
in his contemplation the amount of injury which would arise
generally and in a great multitude of cases not affected by any
special circumstances from such breach of contract.’® After
further comments the Court held that the plaintiff could not
recover the loss of supposed profits.
608. Where the Company Undertakes to Transfer beyond its Line.
In the case of the Adams Express Co. v. Egbert, which was an
action brought by the plaintiff, Egbert, to recover damages
from the Express Company to deliver a box containing plans
and specificatlons for an almshouse at New Orleans to a com-
mittee at that city which had offered a premium of five hun-
dred dollars for the best plan for said house. The Express
Company failed to deliver it until after the appointed day for
.
5 9 Cxch., 341; Sedgwick leading cases on measure of damages, 126;
Lee v, Lancaster & Yorkshire R. R. Co., H. & N., 211.
BAILMENTS. 523
receiving them and until after the premium had been awarded.
The Court, in the examination of the case, suid: “It is doubt-
less true that in all actions for a breach of contract, the loss
or injury for which damages are sought to be recovered must be
the proximate consequence of the breach. A remote or possi-
sible loss is not sufficient ground for compensation. There is
no measure. for those losses which have no direct and necessa-
ry connection with the stipulations of the contract, or which
are dependent upon contingencies other than the performance
of the contract, and which are therefore incapable of being es-
timated. With no certainty can it be said that such losses
are attributable to the wrongful act or omission of him who-
has violated his engagement. But on the other hand the loss of
profits or advantages which must have resulted from the fulfillment of the
contract may be compensated in damages when they are the direct and im-
mediate fruit of the contract, and must have been stipulated for and have
been in the contemplation of the parties when it was made. Applying
this rule to the present case,why was not the loss of the opportu-
nity to compete for the premium an immediate consequ nce of
the breach of the contract? Why was not the loss -in contem-
plation of the parties? The company undertook to transport
the box to the committee appdinted to award premiums. -The
purpose of the contract was to secure the ‘plaintiff in the priv-
ilege of competition. Certainly he must have had that in
contemplation, and if the Company was informed of the ob-
ject of the transmission, the loss of the privilege was in the
view of both parties at the time they entered into the contract.
But whether known or not by the company the loss was the
immediate result of their negligent breach.” The Court held,
finally, that the plaintiff could only recover nominal damages,
as there was no proof that he had lost anything by not being
able to compete for the pre:nium.’
736 Pa. st., 360; opposite 15 Jur., 448,
524 LAW OF DAMAGES.
609. Responsibility of Each Line. Where goods are shipped
under a contract with a common carrier to be carried over sev-
eral independent and connecting lines to their destination at
an agreed through rate, each carrier to receive and carry to the
end of his route and then forward by the next connecting line
and they are lost at the terminus of the route ofan intermedi-
ate carrier, while in his possession, and before delivery to the
next carrier, the intermediate carrier will be responsible for
the damages. And ifacarrier of freight expressly contracts ,
to deliver goods at a destination beyond the terminus of his
own road, he will be responsible for all damages occurring to
.the goods while in the possession of the other company.°
610. His Lien for Freight. A common carrier hasa lien on _
the goods transported by him for the freight due on the whole
route, and he may retain the goods till the freight is paid, but
the payment of the freight and the delivery of the goods are
concomitant or concurrent acts, and if the consignee is ready
and willing to pay the freight due on having the goods deliv-
ered to him, and the carrier refused to deliver them unless he
pays more than is due, the consignee may recover his goods in
an action against the carrier, or sue him for conversion, with-
out making a formal tender of the freight due or bringing the
money into court.
611. His Defense. The law is well settled that a carrier
will be excused from delivering goods when they are, without
any fault or connivance on his part, seized by virtue of a legal
® Erie R. Co. v. Lockwood, 26 Ohio st., 358; Newell v. Smith, 49 Ver-
mont, 255.
The carrier is bound at his peril to deliver the goods to the right per-
son, and if he makes a mistake and delivers the goods to the wrong per-
son he will be held to the owner for their value. Daws., 82.
®* Long v. Mobile & R. R. Co., 51 Ala., 512.
BAILMENTS. 525
process and taken out of his possession. Assoon as the sheriff,
or other officer of the law, seizes the goods by virtue of a writ,
they are then in the possession of the law, and the presump-
tion is that the officer, in levying on them, has done a lawful
act, and the right of the officer to hold the goods involves a
question which can only be determined by a tribunal having
jurisdiction of the subject matter. The carrier is not bound to
stop and settle the title by litigation, but in order to excul-
pate himself from all liability, he must give immediate notice
to the owner of the goods of their seizure, aid unless he
does this he will be held responsible to the owner for all dam-
ages, or the value of the goods.'
If the carrier neglects to use the utmost human care and
foresight to protect the goods in case he is attacked bya public
enemy, or is in the midst of a great storm that threatens to de-
prive him of the goods or to destroy them entirely, he will be
held responsible for the loss. If divers causes concur in the
loss, the act of God or public enemies being one, but not the
proximate cause, it does not discharge the carrier.’
612. Mitigating eT Where the common car-
rier has become responsible for any injury to goods entrusted
to his care he cannot plead in bar of the action that the con-
signee received the goods in their damaged condition, but he
may show that fact in mitigation of the damage; and the
measure of damages will be the value of the goods at the time
'The Ohio & Mississippi Railroad Co. v. Yoke, et al., 51 Ind.. 181;
Redfield on Railways. vol. 2, p. 158; Bliven v. Hudson River R. R., 35
Barb., 191; Van Winkle v. U. S. Mail Steamer Co., 37 Barb , 122; Burton
v. Wilkinson, 18 Vt, 181; sects. 453, 290, and 350 of Drake on Attach; see
also Stiles v. Davis, 1 Blackf., 101.
2 Graham v. Davis, 4 Ohio st., 362; Gordon v. Buchanan, 5 Yerg
(Tenn.) 71.
526 LAW OF DAMAGES.
and place of their destination, less their value in their dam-
aged condition?
613. What the Carrier is Bound to Take Notice of. The com-
mon carrier is bound to take notice of the nature, character
and value of the goods and packages delivered to him, and to
keep them in the way that is the best calculated to preserve
them uninjured.” And in an action against him for injury or
loss of the goods or packages, he will not be permitted to say
that the consignor failed to inform him of the weight, quality,
quantity, character or value of the goods or packages entrusted
to him.
614. Responsibility of Common Carriers of Passengers. The
conimon carrier of passengers is only responsible for those in-
juries arising from his negligence, and he is not the insurer of
the lives of his passengers. He enters into a contract with
his passengers that he will, as far as human care and foresight
can go, provide for their safe conveyance. He is, therefore, not
responsible for accidental injuries, and in case he fails to com-
ply with his contract, he will be held responsible in damages.
And the injured party may recover all loss or injury which is
the proximate result of the breach. But not for remote or
possible losses, or such as depend upon contingencies other
than the performance of the contract, and cannot be estimated.
Thus, in a case against a carrier of passengers to recover dam-
ages for extraordinary detention of the passenger on the route’
and illness thereby occasioned, the court held that plaintifi
1 Bourman vy. Teall, 23 Wend. 306.
* Merch. Dep. T. Co. v. Ballis, 80 Ill. 473; Wiggins v. Boston Railroad
Co., 120 Mass. 201.
° Rice v. K. P. Railroad Co., 63 Mo. 314; .Gaing v. Un. Trans. Co., 28
Ohio st. 418.
* Adams Exp. Co. v. Egbert, 36 Pa. st. 360.
BAILMENTS. 527
could recover for his lost time occasioned by his detention, his
expenses while so detained, the time he lost by reason of his
sickness after his return home, and his loss of health.®
615. Baggage—Responsibility for Loss. The law is pretty
well settled that a common carrier of passengers will be held
as the insurer of such baggage entrusted to his care as is
usually carried by passengers of like station and pursuing a
like journey; but will not be held responsible for such unusual
articles as the exceptionable fancy habit or idiosyncracy of
some particular individual may prompt him to carry.’ He
‘may limit his liability as a carrier of baggage by expressed
contract."
3 Williams v. Vanderbilt, 28 N. Y. 217; see case of Hobbs and wife v.
L. & S. W. R’y Co. L. R. 10 L B. 111; Sedg. Leading Cases on Dam. 155.
®N. Y. C. Railroad’ Co. v. Fraloff, Cent Law Jour. vol. 9, p. 4382; 2
Parson on Cont. 199; Mecrom v. Gt. West. Railroad Co., L. R. 6 Q. B.
121. Whatever a passenger takes with him for his personal use or con-
venience, according to the habit or wants of the particular class to which
he belongs, either with reference to immediate necessity or the ultimate
purpose of the journey, must be considered as luggage. Morow v. Gt.
West. Railroad Co., supra. Soa passenger on a railway by third class
parliamentary train, carry merchandise packed up with his personal
baggage, the railway company is not responsible for the value of the
merchandise if the baggage be lost. 9 Eng. L. & E. 477; Doyle v. Kliser
6 Ind. 242; T W. W. Railroad Co. v. Hammond. 33 Ind 397.
The carrier’s liability extends only to such reasonable articles of bag-
gage, as it is called in Europe, as may be necessary for the traveler’s
convenience, no matter what, or how valuable, other articles may be
which are introduced into the conveyance under the guise of baggage.
The articles of property treated as bagga:e according to the decisions of
different courts may be clothing, traveling expense money, a few books
for the amusement of reading, a watch, a lady’s jewelry for display, etc.
Doyle v. Kiser, 6 Ind. 242; Hawkins v. Hoffman, 6 Hill (N. Y.) 586; Jor-
dan v. Fall River & L. E. Rail. Co.. 20 Ohio 318; The Great North. Rail
Co. v. Shepherd, 9 L. and E. Q. R. 477.
7 Supreme Court U. S. 1879; N. Y. C. Rail. Co. v. Fraloff, 9 Cent. Law
Journal, p. 482.
528 LAW OF DAMAGES.
616. Full Defense. In an action against a common carrier
for the loss of freight and baggage, or for injury to property
entrusted to him, he may defeat the action by showing that
the loss or injury was occasioned by the act of God, or public
enemies, or from the fraud or wilfull misrepresentations of the
consignor or the passenger, and especially when by reason
thereof less care is bestowed upon the property lost or injured
than would otherwise have been. Thus, where a passenger
got aboard a canal boat, deposited his carpet bag with the bag-
gage of other passengers; it contained some clothes, pictures,
etc., and about four thousand dollars in gold coin. It was
stolen from the carrier, suit was brought to recover the value
of the gold, and the court held that the carrier was not respon-
sible’ And he may also defeat the plaintiff’s recovery by
showing that the goods were thrown overboard to save life or
other property, or that the goods perished or were injured from
an inherent defect or cause.’
617. Breach of Contract to Furnish Freight. In an action
brought for a breach of contract to furnish freight, the plain-
tiff’s measure of damages is full compensation for all loss sus-
tained. And in the absence of proof he may recover the
contract price, if the suit is brought after the time the freight,
according to the contract, was to be delivered at its place of
destination. When one party toan executory contract refuses
further to comply with it on his part, the other party has an
immediate cause of action for said breach, and he may sue on
it at any time and recover the damages which he may have
sustained by being deprived of the benefit accruing to him
under it. And if he treats the contract at an end and sues at
® Doyle v. Kiser, 6 Ind. 242
‘2 Parson on Contract, 673; Rute v. Mich. Cent. Rail. Co., 1 Biss. 35;
Stoneman vy. Erie Rail. Co , 52 N. Y. 429: Reed v. Phil. ete. Rail. Co., 3
Haust (Del.) 176. See authorities above.
BAILMENTS. 529
once upon its breach, his damages are to be measured by the
value of the contract to him at the time it was broken, and
this value is estimated by the profits he would have realized
during the continuance of the contract had it been faithfully
carried out. The jury or court in estimating the plaintiff ’s
profits should first take the contract price and ascertain the
exact amount that would be due the plaintiff on the comple-
tion or fulfillment of the contract; and then deduct from this
amount every item of costs and expense necessarily attending
a full compliance on his part.’
618. But where suit is brought, as we have already said,
after the expiration of the time the service was to have been
performed, then the plaintiff will be, prima facia, entitled to
recover the contract price. But the defendant may show, in
mitigation of damages, that the plaintiff could, by the use of
reasonable meuns or diligence, have procured other work, and
that he failed to do so, or that he did procure other work at a
fair price; and where this is done the plaintiff can only re-
cover the difference between the contract price and the price
he did, or might have received.’
1 Morrison v. Lovejoy, 6 Minn. 319; Fox v. Harding, 7 Cush. 516; Cun-
ningham y. Dorsey, 6 Cal. 19; Hecksher v. McCroy, 24 Wend. 309;
Shannon vy. Comstock, 21 Wend. 457; Masterton v. Mayor of Brooklyn,
7 Hill 61; Sedgwick on dam. 364; Dunn v. Johnson, 33 Ind 54,
? Morrison v. Lovejoy, supra; Cortegan v. The M. & H. Rail. Co., %
‘ Denio 609; Hamilton v. McPherson, 28 N. Y. 72; Hecksher v. McCroy,
supra; Shannon v. Comstock, 21 Wend. 457.
CHAPTER XXXV._.
TELEGRAPH COMPANIES.
“4
TELEGRAPH CoMPANIES. THEIR RigHtT To Contract. THE
RULE OF RESPONSIBILITY. GENERAL POWER TO CONTRACT.
PowER TO LIMIT LIABILITY. RESTRICTION OF LIABILITY.
THEY CANNOT BY CONTRACT BE MADE RESPONSIBLE FOR NEG-
: LIGENCE, &c. STATUTES AND COMMON LAW. DaMaGEs. GEN-
ERAL IN ASSESSING FOR MISCONDUCT.
619. Telegraphing. Not quite a half century ago, by the
great skill, genius and untiring energy of Professor Morse, the
means of communicating thought by t.e electro-magnetic tel-
egraph was first discovered, and the lightning harnessed for
the use of man. It has since that time become a very efficient
agent in the transaction of business and in carrying on trade
and commerce between different sections of the country; and
its wires cover, like spider webs, the whole land, span the
two continents and “closely unite us with the old world.” The
interests of society demand that a business of such magnitude
and importance should be regulated by well defined rules of
law to compel prompt action, guided by care and prudence so
TELEGRAPHING. 531
that the public, who may have occasion to use this means of
transmitting messages, have a reasonable protection against
neglect, or fraud, or want of due care on the part of the com-
pany. And the courts have, as far as possible, applied the
rules of law governing common carriers to the business of tel-
egraphing."
620. The Power of a Telegraph Company to Contract. The
authorities are uniform in holding that a telegraph company
has a right to make reasonable rules and regulations for the.
proper conducting of its ordinary telegraphing business, and
this right is now recognized by many of the States by statu-
tory enactments, and in others by the decision of the Supreme
Courts. But they cannot by contract exempt themselves from
all responsibility for want of fidelity and care in the exercise of
the employment by which they undertake to prosecute. There
are duties that they owe the public, arising out of the nature
of their employment which would be impolitic and inexpe-
dient to suffer them to diminish or evade. Among these
duties may be mentioned the obligation of employing compe-
tent and skilled operators, and other agents and servants, in
all respects competent to discharge their duty.
' MacAndrews v. Electric Tel. Co, 17 C B. 3; Parks v. Ata. Cal. Tel.
Co, 13 Cal. 422; Rittenhouse v. The Ind. Tel. Line. 1 Daly (N. Y. Com.
Pleas) 475: West. Un. Tel. Co. v. Graham, 1 Colorado 203; 8. C. 9 Am.
R. 186; Baldwin v. U.S. Tel. Co., 1 Lam. (N. Y.) 125: 8. C. 45 N.Y.
744; McAndrews v. The Elec. Tel. Co., 33 Eng. Law & Eq. 180; Bowen
v. Lake Erie Tel. Co., 1 Am. Law Reg. 685; Parks v. At. Tel. Co., 13 Col.
422; Bryant v. The Am. Tel Co., 1 Daly 575; Washington & N. O. Tel.
Co. v. Hobson, 15 Gratt (Va.) 122; Tyler v. U.S. Tel. Co., 60 Ill. 421;
W. U. Tel. Co. v. Crew, 15 Mich. 525; Leonard v.N Y. etc. Tel. Co.,
41 N Y 544; Prins. Tel. Co. v. Durburgh, 35 Penn. 298; DeRuth v. N.
Y. Al. & Ruff. Tel. Co., 1 Daly 547; S. C. 30 Howe Pr. 403; Smithson v.
U.S. Tel. Co., 29 Md 162; Ellis v. Am. Tel. Co., 13 Allen 226; Allen Tel.
cases, 663; Breen & M. V.v U.S Tel. Co., 45 Barb. 272; 8. C. 48 N. Y.
132. :
2 Western Union Tel. Co. v. Graham, 1 Colorado 230; 9 Am. R. 136.
532 LAW OF DAMAGES.
621. The General Rule of Limitation. The rule is universal
that men who engage in a certain occupation, employment or
business, are bound to the use of due and reasonable care and
are liable for the consequences of carelessness or negligence in
the conduct of their business to those sustaining loss or dam-
ages thereby. “And this rule is applicable to the business of
transmitting messages by telegraph. But the rule does not
operate so as to prevent parties from prescribing reasonable
rules and regulations for the management of their business, or
establishing special stipulations for the performance of ser-
vices which, if made known to those with whom they deal,
and directly, or by implication assented to by them, will oper-
ate to abridge their general liability at common law, and to
protect them from being held responsible for unusual or pe-
culiar hazards which are incidental to particular kinds of
business. But a party in this way cannot protect himself
against the consequences of his own fraud or gross negligence,
or the fraud or gross negligence of his servant or agent ; nor
can he escape all liability or responsibility in the performance
of the service or duty that he undertakes. Nor can there-be
any difficulty or danger in the application of this principle,
so long as it be kept within the proper limits. That limit is
found by requiring in all cases that the conditions and regu-
lations. by which a party seeks to limit his liability in the
conducting of his business shall be reasonable. And the law
will only permit him to prescribe such, and to none other can
those who deal with them be held to yield their assent.” *
4 Elis v. Am. Tel. Co., 13 Allen 234.
The courts and legislatures have been liberal in allowing companies
to provide against such risks as arise out of atmospheric influences and
kindred causes. But to permit them to contract against their own neg-
ligence would be to arm them with a most dangerous power; one indeed
that would leave the public almost remediless. It must be borne in
mind that the public have but little choice in the selection of the com-
pany which is to perform the desired service. They do not select the
TELEGRAPHING. 5383
622. From what we have said we think the following
rules may be laid down: 1. Such company may adopt and
enforce such rules and regulations for the convenient, prompt
and satisfactory performance of the act or duty undertaken.
2. This right in the company is absolute and unlimited, but
such rules are subject to tests of reasonableness, in view of the
rightful claims of public policy and private rights, and the
enforcement of the obligation of good faith and honest effort
to perform. 3. The test must be applied by the court when-
ever the question arises on the validity of such regulations,
according to the rules above stated.” A rule that releases the
company from all liability for all possible delinquencies, mis-
takes, delay or neglect in transmitting or delivering a mes-
sage, from whatever cause, would be against public policy, and
void. The law has placed a bound to the power of the com-
pany to limit its legal liabilities. It does not rest with such
companies to fix the conditions of their contracts absolute, by
which they may avoid duties and responsibilities by their
mere will, or by their view of self interest or desire to shield
the company or its officers from liability or the direct conse-
quences of their neglect or carelessness. “The public and
those who employ» their agencies to perform important ser-
vices, have rights which cannot be ignored or avoided by
stipulation made by interested parties. When a company
assumes the position of offering its services generally to all
who may apply, under its character of a public corporation, it
does not stand exactly in the same position as a private indi-
agent or employer, nor can they remove them. They are bound to take
the company as they find it, and to commit to its agent their messages,
however valuable they may be. Such being the case, public policy as
well as commercial necessity, requires that companies engaged in tele-
graphy should be held to a high degree of responsibility. Bering v. N.
Y. & W. Tel. Co., 18 Md. 341.
260 Me. 9.
534 LAW OF DAMAGES.
vidual contracting in a single matter, on terms and conditions
mutually agreed upon for thot particular case.” *
623. The Power of Telegraph Companies to Limit their Liabilities.
We have seen that the validity of a telegraph company for
mistakes, &c., is to be tested by reason. If the rule is unrea-
sonable, then it will be disregarded by the courts. And we
think that among the rules which should be considered un-
reasonable is the one that exempts the company from all liabil-
ity for its own negligence and mistakes. Aside from the ob-
jection resting on the ground of public policy, and which for-
bids the company from stipulating for immunity from the
consequences of its own wrongfulact it is very clear that such
a contract should be held void for want of consideration. The
company enters into a contract'with the sender of the dispatch,
and takes upon itself the burden of some sort of legal obligation
to send the message, or it does not. It would be manifestly
against reason and what all must assume to be the intention of
the parties to say that no contract whatever is made between
them, and nobody, not even the representatives of the company
assert such a doctrine, and it is entirely absurd to assert it. For
the company holds itself out as ready and qwilling and able to
perform service for whomsoever comes and pays the considera-
tion itself has fixed and declares to be sufficient to remunerate
it for the service. A legal obligation at once arises and a duty
devolvesupon the company to transmit the message with rea-
sonable care and diligence, according to the request of the sender.
This being true, the question at once arises whether it can at
the same time, andas a par’ of the very act creating the obli-
gation, exact and receive from the other party a release from
it. It would completely nullify the contract by absolving the
* True v. International, etc., 60 Me. 9; Leonard v. N. Y. etc. Co., 41 N.
Y. 544; Tel. Co. v. Dryburgh, 35 Pa. 298; Derute v. N. Y. Al. & Buff. Tel.
Co., 1 Daly (N. Y.) 547; Ellis v. Am. Tel. Co., 13 All. 226.
TELEGRAPHING. 535
company from all obligation to perform it, and the party deliv-
ering the message, gets nothing in return for the price of trans-
mission paid by him. It is not possible for a party entering in-
to a contract upon a valuable consideration, to promise and not
to promise, or to create and not to create an obligation of duty
at one and the same moment, and by one and the same act.®
624. The General Rule in Regard to the Limitation of Responsi-
bility. We think it may be laid down as a general rule, gath-
ered from all the authorities, that telegraph companies may,
within certain limits, establish rules and regulations governing
the manner of sending messages, repeat messages, and the price
to be paid for messages, repeat messages and insured messages,
but they cannot make such rules and regulations as will pro-
tect them from the consequences of their own fraud or gross
neglect, or from the fraud or gross neglect of their servants or
agent.'
‘
625. Contract in Restriction of Liability. The Court of Ap-
peals of the State of New York in commenting ‘on the ques-
® Candee v. Western Tel. Co., 8 Alb. Law Journal, 2938. 1
The Supreme Court of Iowa has held that while a regulation as to re-
peating messages is reasonable it will only absolve the company from
liability for mistakes caused by uncontrollable sources, such as atmos-
phere or électricity, and that, notwithstanding such regulation; the com-
pany was bound to employ skillful operators, use’ proper instruments,
and to exercise reasonable and ordinary care in the transmission and de-
livery of messages. Manuelv. Western Union Telegraph Co., 7 Western
Jurist, 611.
1True v. the International Telegraph Co., 60 Me., 9; same, 11 Am. R.,
156; Ellis v. The Am. Tel. Co., 13 Allen, 234; Berny v. N. Y. & Wash.
Tel Co., 18 Md., 341; Western Union Tel. Co.,v. Buchanan, 35 Ind., 429;
McAndrew y. The Elect. Tel. Co., 17 C. B. 3; Camp v. Western Union
Tel. Co, 1 Met. (Ky.), 164; Warm v. W. U. Tel. Co., 37 Mo., 472; W. U.
Tel. Co. v. Casen, 15 Mich., 525; W. U. Tel. Co. v. Graeam, 1 Colorado,
230; same, 9 Am. R., 186; Bryant v. Am. Tel. Co.,1 Daly, 575; U.S.
Tel. Co. vy. Gildersleeve, 29 Md., 232; Smeatherd v. Ill. Tel. Co, 27 la,
285; Beese v. U.S. Tel. Co., 48 N. Y., 182; 8 Am. R., 526; W. U. Tel. Co,
v. Fenton, 52 Ind., 1; W. U. Tel. Co. v. Meek, 49 Ind., 53.
536 LAW OF DAMAGES.
tion of the power of a telegraph company to restrict its liabil-
ity by contract, said: “Telegraph companies may, in one sense
be called common carriers, as they are engaged in public em-
ployment, and are bound to transmit for all persons messages
delivered to them for that purpose. But if we call them com-
mon carriers in this sense it does not follow that they become
insurers like common carriers of goods. In the absence of any
special contract they do not insure the! accurate transmission
of messages, but they are bound to transmit them with care
and diligence adequate to the business which they undertake.
But they have a right to make reasonable rules for the conduct
of their business. They can thus limit their liability for mis-
takes not occasioned by gross negligense and willful miscon-
duct, and this they can do by notice brought home to the send-
er of the message, or by special contract.’
626. And it may be laid down as a general rule that tel-
egraph companies have no power to restrict their duties or li-
abilities by a mere notice, unless that notice is brought to the
knowledge of the party who employs them to send dispatches.
There must be an expressed or implied contract between the
company and the sender of the messages to the effect that the
company is exempt from certain liabilities, which it would
otherwise be responsible for.
627. Statute and Common Law. The statutes of several of
4 Breeze v. U.S. Tel. Co., 48N. Y., 132.
5 Birny v. N.Y. & W. Tel Co., 18 Md., 341; U. S. Tel. Co. v. Gil-
dersleeve, 29 Md., 232; Breeze v. United States Telegraph Co., 48 N. Y.,
182; Cole v. Goodwin, 19 Wend., 259; Western Transpt. Co. v. Hall, 24
Ill., 466; Falvey v. Northwest Transp. Co., 15 Wis., 129; State v. Sausser,
37 Ala., 247; Camp v. West Union Tel. Co.,1 Met. (Ky ), 164; Warm v.
the Western Union Tel., 37 Mo., 429; Ellis v. The Am. Tel. Co., 13 Allen
226; W. U. Tel. Co. v. Crum, 15 Mich., 525; Parks v. The Atlantic &
California Tel. Co, 13 Cal., 422; The N. Y. & Wash. Tel. Co. v. Day-
bury, 35 Pa. st., 298; Western Union Tel. Co. v. Buchanan, 35 Ind., 429.
4
TELEGRAPHING. 537
the States contain provisions that telegraph companies shall
use the most approved instruments in use; and where this is
not required by the municipal law of the State, the common
law rule supplies the deficiency, and requires that the best
instruments known to the business shall be used by the com-
pany. They must treat all alike. Where the press of busi-
ness makes it impossible to send all the dispatches that may
be presented, they will be excused from receiving’ the same.
They must send the dispatches in the order they are received,
They must be reasonably prompt in dispatching messages,
But the most important obligation is to send them accurately
that is, as they are written. They cannot be changed by the
company in any respect or particular. If the agent cannot
read it he should reject it at once; but if he receives it he
must read it as well as he can, and send it as he reads it. He
must not alter it to the extent of abridged words, or to im-
prove the grammar or the spelling, or amend it in any way;
for it may be that he cannot comprehend or understand it, and
yet the party receiving it may comprehend it at a glance.
The company is under obligations to keep secret all dispatches
intended to be transmitted toa third person; but these are not
privileged communications. They must be prompt in deliy-
ering messages received by them, to the right person. If they
receive a message directed to a person beyond their own line,
they must send it to the place of destination, even if they
have to employ other companies for the purpose. And the
question as to the responsibility of a different line, to the
sender, for a failure to transmit the dispatch to the designated
person, will depend very much upon the circumstances. If
the other lines are not associated with their’s in such a man-
ner as to forma partnership, they will be responsible. In
employing companies of this kind to transmit dispatches, the
question at once arises as to the nature and character of the
N
538 LAW OF DAMAGES.
contract. If there is no expressed agreement the law fixes the
liability of the parties.‘
628. Damages. The question of the measure of damages
in this class of cases is one not free from difficulty. The card-
inal rule undoubtedly is that the injured party shall recover
all the damages which have been occasioned by the failure of
the other party to comply with the terms of the contract; but
this rule is modified in its application by two others: 1. The
damages that can be recovered must flow directly and natur-
ally from the breach of the contract. 2. They must be certain
both in their nature and the course from which they proceed.
And the law may now be considered settled that the plaintiff
cannot recover speculative, contingent and remote damages or
probable gains, or contingent profits. He can only recover
such damages as may fairly be supposed to have entered into
the contemplation of the parties when they made the contract
as might naturally be expected to follow its violation, suppos-
ing they had given the matter their careful attention and
considering all the circumstances surrounding them. Thus,
where a company failed to send.a dispatch from Chicago to
Oswego, N. Y., and by reason of such failure the plaintiff
was prevented from purchasing a large quantity of salt, the
court held that the measure of damages was the difference in
the price of salt in Chicago and Oswego on the day of ship-
ment, together with the increased charge for transport-
ation, deducting costs of transportation when the salt
should have been shipped But where a person has
been disappointed in receiving goods, or in making
a purchase, the law requires him to use due diligence in
order to protect himself from loss; and if an article of the
same kind can be readily procured in the immediate neigh-
borhood at the same price, he must make the purchase, and if
*Deruth v. Albany Tel. Co., 1 Daby, 547; Leonard v. Y. Albany &c.
Tel. Co., 41 N. Y., 544; Baldwin v. U. S. Tel. Co., 1 Loring, 125.
TELEGRAPHING. 539
he fails to do so, his damages will be reduced. He cannot at
once abandon all attempts to procure the article and rest upon
a claim for indefinite or posible profits which he may make in
the rise in the price. The law requires him to use reasonable
diligence after the notice of the failure to procure the same
article, and if it is to be transported, the same or lower rates
of freight. The sum that a plaintiff can recover is the direct
loss or injury by reason of the negligence of the defendant, is
the difference between the price of the artiele and the price
the plaintiff would be compelled to pay after due and reasona-
ble diligence to purchase the same article at the same place»
and the price he was to pay for the article, and the increase of
freights. The company must in all cases make good the direct .
loss.” And this rule applies to parties who have been disap-
pointed in sending dispatches for goods, or in making con-
tracts.1. Thus, it was held when the defendant failed to deliver
a message ordering a certain quantity of goods, which resulted
in a loss to the plaintiff by reason of a sudden rise in the
market, that the measure of damages was the difference be-
tween the value of the goods at the price named and the sum
which the plaintiff, in the exercsie of reasonable diligence
after notice of the default of the telegraph company would
have been compell-d to expend in purchasing the same quan-
tity and quality of goods.’
629. The General Rule of Damages. We think it may be
7 True v. International &c., 60 Me., 9; same, 11 Am. Rep, 156; Squire
v. West. Un. Tel. Co., 98 Mass , 322; Parks v. Atlantic Co., 13 Col., 422;
Bryant v. Am. Tel. Co., 1 Doly, 575; Bowen v. Lake Erie Co., 1 Am.
Law Reg 685; Ritieabanm v. Ina Line of Tel , 1 Daly, 474, W. & N. 0.
Tel. Co. v. Hobson, 15 Grat, 122; Griffin v. Colver, 16 N. Y. 490; Leon-
ard v. N. Y. Tel Co., 41 N. Y., 544; 1 Am. Rep., 446- Freeman v. Clute, 3
Barb., 426; Blanchard v. Eli, 21 Wend , 342; Hadley v Baxendale, 26 E
L. & E., 398.
1 Miller v. The Maumcheck, 7 Greenl., 51.
2 Squires v. Western Union Tel. Co., 98 Miss., 232; True v. Interna-
jional Tel. Co., 60 Me., 9.
540 LAW OF DAMAGES.
laid down as a general rule that telegraph companies will be
held liable for all the direct damages which both parties to the
contract would have contemplated as flowing from its breach
if, at the time they entered into it they had bestowed proper
attention upon the subject, and had been fully informed of all
the facts. And that they are not liable for remote or specula-
tive damages, although susceptible of proof and deducable
from their neglect or refusal to carry out their contract.’
630. The Washington & New Orleans Telegraph Company v.
Hobson. This was an action against the “telegraph company
for damages sustained by the plaintiff in consequence of a
mistake in the transmission of a message on their line where-
by an order to the plaintiff’s factors in Mobile to buy five
hundred bales of cotton was altered to twenty-five hundred.
The factors bought two thousand and seventy-eight bales of
cotton before the mistake in the message was ascertained. It
was held that if the company was liable to the plaintiffs for
the damages arising from the alteration of the message, the
commissions of the factors upon the purchase of the cotton
were a part of the damages for which the company is liable,
and that the plaintiffs were not bound to accept any offer of
the company to pay the damages, which excluded these com-
missions. The court said the measure of damages is what is
lost on the sale of the excess of the cotton at Mobile, or if not
sold there, what would have been the loss on the sale of the
"True v. The Int. Tel. Co., 6 Maine 9; same 11 Am. Reg. 150; West.
Un. Tel. Co. v. Graham, 1 Colorado 230; Bery v. Dunill, 44 Me. 255; Per-
kins v. P.S. & P.R., 47 Me 592; Riply v. Mossly, 57 Me. 76; Squire v.
W. U. Tel., 98 Mass. 232; Griffin v. Colver, 16 N. Y. 490; Leonard v. N.
Y. Tel. Co., 41 N. Y. 544; same, 1 Am. Rep. 446; Freeman v. Clute, 3
Barb. 426; Blanchard v. Ely, 21 Wend. 342; Miller v. The Mar. Church,
7 Greenl. 51; Leonard v. N. Y. ete., 41 N. Y.544; 1 Am. Rep 446; Lane
v. The Montreal Tel. Co., 7 Upper Can. Com. Pleas Rep. 23; Wash. etc
Tel. Co. v. Hobson, 15 Gat. 122; Shields v. Wash. Tel. Co., 9 West. Law
TELEGRAPHING. 541
cotton at Mobile in the condition and under circumstances
which it was when the mistake was ascertained, including in
such loss all the proper costs and charges thereon. When the
mistake was ascertained a part of the cotton was on board a
ship to be sent to Liverpool, a part was under contract of
affreightment to the same place, but not on board. The whole
should have been sold as it was at Mobile; and the plaintiffs
having sent it to Liverpool and sold it there, the loss.of the
company is not to be increased by this act of the plaintiffs,
but must be based on an estimate of what it would have sold for
a part on shipboard and a part under contract of affreightment.
If the plaintiff sent the cotton to Liverpool for the purpose of
speculation, with the intention of taking to themselves the
profits, if any, and in the event of a loss visiting the loss on
the company, they are not entitled to recover any loss sus-
tained upon it. But the plaintiffs sent the cotton to Liver-
pool, not with the purpose of taking profits, if any, but only
to indemnify themselves out of the proceeds to the extent of
the costs and obligation incurred by them, they do not thereby
lose their right to recover from the company the damages
which they would have sustained if the cotton had been sold
at Mobile. The plaintiffs, if they intended to hold the com-
pany responsible for the excess of the cotton purchased should:
as soon as they were apprised of the purchase, have notified
the company of such intention; should have made a tender of
such excess to the counpany on the condition of its paying the
price and all the charges incident to the purchase, and also
that, in case of its refusal to accept said tender and comply
with its conditions, they would proceed to sell such excess at
Mobile, and after crediting said company with the next pro-
Journ. 283; Lardsberger v. Magnet Tel. Co , 32 Barb. 530; Geldersleeve,
29 Md. 232; Rittenhouse v. The Ind. Line of Tel., 44 N. Y. 263; 4 Am.
Rep 673; Tyler v. W. U. Tel. Co.. 60 Ill. 421; Hubbard v. W. U. Tel.
Co., 33 Wis. 558; W. U. Tel. Co. v. Fenton, 52 Ind. 1.
1
542 LAW OF DAMAGES.
fits, would look to it for the difference between the amount of
such proceeds ‘and the costs of the excess, including all proper
charges; and upon a failure of the company, after notice to
accede to their offer, they should have proceeded accordingly.”
631. Hadley v. Baxendale The rule laid down for the as-
sessment of damages in the case of a breach of contract in this
famous case, that we have referred to so frequently in this
work, applies in the case of a breach of a contract to send tele-
graph dispatches. It isa practical rule founded on a wise pol-
icy and at the same time consistent with good sense and
sound equity; it is that the defendant can be held liable for a
breach of contract only, for such damages as are the natural or
necessary result of the breach, such as may fairly be. supposed
to have been in the contemplation of the parties when they
made the contract, as the probable result of a failure to com-
ply with its stipulations. By this rule, all remote speculation
and uncertain result, as well as possible profits and advan-
tages, and other like consequences which might have arisen
from a fulfillment of the contract is excluded, as forming no
just or legitimate basis on which to determine the extent of
the injury actually caused by the breach.’
634. Mistake in Sending Dispatch to Ship Owner. In the case of
Lane v. the Montreal Telegraph Company. The plaintiff, a
ship owner, having been induced, by error of the defendant in
the transmission of a message, to suppose he could obtain a
cargo of eight thousand instead of three thousand bushels of
wheat from Chatham to Oswego, abandoned a contract for a
"The Wash and N. O. Tel. Co. v. Hobson, 15 Grat. 122,
19 Ex. 341.
* Squire et al v. West. Un. Tel. Co., 98 Mass. 232; Field on law of dam.
Sec. 414.
TELEGRAPHING. 543
cargo from Detroit, and sent his vessel to Chatham, whence it
sailed with a cargo of three thousand bushels only. Held,
that the damages which naturally result from the defendant’s
breach of duty were the expense of sending the vessel to Chat-
ham and back, and that the plaintiff was not entitled to claim
the profits he might have made from carrying the eight thou-
‘ sand bushels?
633. Mistake in Sending Dispatch for a Shawl. In Bowen v.
The Lake Erie Telegraph Company, a telegram was sent to
the plaintiffs, who were merchants, and when delivered, was
as follows: “send one handsome cight dollar blue-orange.” By
mistake of the company in the transmission, the telegram, as
delivered to the plaintiff, was as follows:. “send one hundred
eight-dollar blue and orange.” The plaintiff accordingly sent
one hundred shawls of that description to the signer of the mes-
sage, who returned them to the plaintiff, and the shawl season
having closed they were depreciated in value. Held, that the
plaintiff might recover the loss.*
634. Miitake in Sending Dispatch for Money. In the case of
of Lowery v. the Western Union Telegraph Company, “One
Brown sent a dispatch by the defendant’s line to the plaintiff,
asking for five hundred dollars. By the negligence of the de-
fendant’s employes the sum named was changed to five thou-
sand dollars, which the plaintiff sent to Brown, who absconded
with it. In an action for damages, the referee allowed the
amount of the loss. This was held to be wrong, as Brown’s em-
bezzlement did not naturally result from the defendant’s
neglect.’
3 7 Upper Canada Com. Pleas Rep. 23; see Wash. etc. Tel. Co. v. Hob-
son, 15 Grat 122.
*1Am. Law Register, 685; TheN. Y. & Wash. Bostgn Tel. Co., 35 Pa.
st. 298.
. 260 N. Y. 198. }
t
/
544 LAW OF DAMAGES.
635. Mistake in Sale of Stock. In the case of Rittenhouse
v. The Independent Line of Telegraph, the plaintiff delivered
at the defendant’s office, to be transmitted to a broker in New
York, the following telegram ; * “Tf we have any old Southern
on hand, sell the same before’ Board. Buy five Hudson at
Board.” In transmission Hudson was changed to hundred and ~
the broker thereupon bought five hundred shares of old-South-
ern (Michigan Southern Railroad). Plaintiff hearing of this
directed the sale of the Southern, and the purchase of five
hundred shares of Hudson River, according to the intent of
the original messege, and which, it appeared, would have been
understood by the broker if correctly transmitted. In the
méan time Southern fell and Hudson rose, entailing a loss of,
on the saleof the former of four hundred and seventy dollars,
and on purchase of the latter of thirteen hundred and seventy-
five dollars, The court below held the measure of damages to
be the loss on the purchase of the Hudson, but declined to al-
low the loss on the sale of the Southern, on the ground that
the stock was in legal effect on the defendant’s account and
could not be sold without some notice to them. The court of
appeals affirmed the judgment, and expressly stated that the
$1,375, the loss in purchasing the Hudson, was the measure of
damage.*
636. Delay in Delivering, and Neglect in Sending a Dispatch.
In the case of Bryant v. American Telegraph Company, the
plaintiff sent a message to the defendant’s office in New York,
addressed to an attorney in Providence, Rhode Island, direct-
444 N, Y. 263; Shields v. Washington Tel. Co., West. Law Journal
283. When it appeared that a dispatch was delivered by the plaintiff to
be transmitted by the defendant, directing the purchase of wheat at a
limit of ‘ 22,” it was changed to “ 25,” in consequence of which the wheat
was purchased at a price that proved a loss of more than $2,000. The
court held that the loss could be recovered. Rittenhouse v. The Ind-
Line, 1 Daly 474.
TELEGRAPHING. 545
ing him to attach a house and lot in that city of one B, who
was then temporarily absent from Rhode Island, for a debt of
$12,000 due by B’s firm to the plaintiff. The message was
brought to the defendant’s office at half past eight p. m., which
was then closed for the ordinary transaction of business.
Their agent was told that the message was important, and
that unless it was sent and delivered at once it would be of no
use; that the object of the message was to get an attachment
upon property in Providence; that unless it was made before
the Stonington train reached the Rhode Island State line it
would do no good; that he would consequently see the impor-
tance of the matter, and why the plaintiffs were so urgent.
The defendant’s clerk answered the plaintiff’s messenger that
the message would be sent and delivered as he wished, and
that he would not take the money if he thought there was
any doubt. The message was sent ten minutes paet nine, with
directions from the operator to send it in haste, and was re-
ceived by the operator in Providence at half past nine p. m.,
who was then engaged in receiving report for the press, which
by the statute had precedence over all other matter. The
Providence operator answered that it could not be sent that
night, as the delivery boy had gone home ; to which the other
answered that it must be, and the former replied by a sign
expressing his concurrence. The Providence operator was en-
gaged without cessation in receiving newspaper reports until
half past eleven o’clock p.m., when he had the message copied
and sent to the attorney. When the attorney received it it
was too late to have an attachment inade before the arrival of
B, who returned to Rhode Island on the Stonington train that
morning, and the plaintiff lost the advintage of securing the
debt by an attachment on B’s house and lot, which was worth
$12,000. B’s firm afterwards went into bankruptcy, and all
the plaintiff recovered upon the debt from the bankrupt es-
tate was $500. Held, that the plaintiffs were not bound to
546 LAW OF DAMAGES.
exhaust their legal remedy against their debtors by the recov-
ery of a judgment ‘and issuing an execution before bringing an
action against the telegraph company for the recovery of dam-
ages; ulso that the measure of damages was the amount of the
debt and interest from the date of the delivery of the mes-
sage, less the $500 which the plaintiffs had received from the
bankrupt estate of B’s firm.’
637. Damages Limited—Interest. In one case a message was:
sent requesting a party to get $10,000 of Mail Company. “The
$10,000 was in the hands of the Mail Company, and intended
by the party sending the dispatch for a certain use.” But the
message, which was addressed “ Landsburger,”’ was received
and directed “Lanmeyer,” and by reason thereof some delay
occurred, and the chance to use the money to profit, as intend-
ed, was lost. The telegraph company had no notice whatever
of the special purpose for which the money was to be used.
The court said: “The defendant was not informed of any
special use intended to be made of the sum of money, and
what damage they would naturally expect to follow from
the receipt of it. Clearly, the loss of the use of that sum
during the time that its receipt was delayed, and the
damage for the loss of such use, are by the laws of New York
determined by the interest on the money. This being true,
the court held that it could not be assumed that, the parties,
when they made the contract, contemplated the pecuniary loss
as the natural or probable result of the breach of it; or a fail-
ure to send the message, and in case the company would
only be liable for nominal damages, or to refund the price paid
to send the dispatch. So that the rule laid down in the case
of Hadley v. Baxendale did not apply.®
5 Bryant v. American Tel. Co., 1 Daly 575.
®16N, Y. 424; Landensberg v. The Mag. Tel. Co., 32 Barb 530; Shield
v. Wash. Tel. Co., 9 West. L J 283; U.S. Tel. Co. v. Gildersleeve, 29
Mad. 233; Candee v. U.S. Tel. Co., 34 Wis. 471.
TELEGRAPHING, 547
638. Omission or Refusal to Send a Message. It is now gen-
erally conceded by courts and law writers that it is competent
for telegraph companies to provide by rules and regulations
against unforseen disarrangements of electric apparatus and
the imperfection necessary incidented to the transmission of
signs and words by electricity. But these forces or accidents
do not affect the ability of the company to deliver the message
to the party addressed after it has been taken off the wires and
reduced to writing.’
639. The Liability of Different Companies who Transmit the Same
Message. As we have already intimated there seems to be quite
adiversity of opinitn among courts and law writers in refer-
ence to the liability of telegraph companies receiving messages
to transmit over its own and other wires, where injury results
from the negligence of the latter. It is settled in England that
the first receiver is only responsible to the consignor.' But in
this country the rule is distinctly opposite.’
< West. Un. Tel. Co. v. Graham, 1 Colorado 230; N. Y. & Wash. Tel.
Co. v. Dyburgh, 35 Pa. st. 298.
Murschampt v. Lancaster, etc. Railroad Co, 8 M. & W. 421; Scott-
horn v. South. 8S. Railroad Co., 8 Exch. 341; 8 Eng. L. E. R. 287; Bristol
Railroad Co. v. Cullins, 7 H. L. Cos. 194; Hulston v. Norman, 969; 11
Exch. 690; Caxon v. Gr. West. Railroad Co.,5 H & N. 214; Mytton v.
Mid. Railroad Co., 4 H. & N. 615.
1 Nutting v. Conn. Riv. Railroad Co., 1 Gray 502; Hood v. N. Y. &N.
H. Railroad Co., 22 Conn. 1; id. 509; Farm. and Merch. Bank v. Cham-
plain Trans. Co., 23 Vt. 186; Dennetter v. Allegheny etc. Tel. Co., 1
Daly 547.
CHAPTER XXXIX.
LIQUIDATE DAMAGES.
Liqguipare Damaces Derrinep. RuLes oF CoNnstRUcrion.
THE AGREEMENT OF THE PARTIES TO CONTRACT WHEN IT CAN
BE CLEARLY ASCERTAINED RuULE IN ENGLAND. RULE IN
THE UNITED STATES.
640. Liquidated Damages. The parties to a contract havea
right to fix the amount of damages in advance of the breach of
it, in any sum, however disproportioned to the real damages,
they may see fit and proper. And the sum thus fixed is
called liquidated damages. And where the parties have, by
agreement, fixed the amount of damages that shall be recov-
ered from the party in default, the courts are bound to enforce
the contract, and the plaintiff’s recovery will be limited to
the stipulated amount, whether it be more or less than the
real damages.
641. Construction. Owing to the fact that men of means
are apt to take advantage of those who are laboring under
LIQUIDATE DAMAGES. 549
financial embarrassment, and fix the amount of damages ata,
sum greatly in excess of the real damages, courts have adopted
the most rigid rule for the construction of contracts of this
character. But when the intention of the parties can be clear-
ly ascertained, the law makes it the duty of the courts to en.
force the contract according to that intention. The rule
adopted, and which are generally recognized by the courts for
the construction of contracts of this character are as follows:
1. The language of the agreement is not conclusive, and
the effort of the court is to learn the intention of the parties.
The term liquidated damages in a contract is not conclusive
evidence that the parties intended to fix the amount of dam-
ages at a specific sum, if the court can discover in other parts
of the instrument reasons to even doubt the intention of the
parties.
‘2. Where the word penalty is used it is generally conclu-
sive evidence against the stipulated amount to be held as liq-
uidated damages, however strong the language of the instru-
ment favors such construction.
3. If the sum stipulated is to be paid on the non-pay-
ment of a less sum which is certain in amount, (or can be
easily ascertained) and made payable by the same instrument,
then it will be treated as a penalty.
4, If the sum be evidently fixed to evade the usury or
any other statutory law, or to cloak oppression, the court will
relieve the defendant by treating it as a penalty.
5. Where the contract contains stipulations or covenants
for the performance of several things of various degrees of im-
portance, and asum is specified in general terms to be paid on
the breach of the contract, and even though it be designated
as liquidate damages it will be treated as a penalty.
6. When the agreement is in the alternative to do an act
or pay a given sum of money, the court will hold the party
c
550 LAW OF DAMAGES.
failing to have elected, and will compel him to pay the
amount of money specified.
7. If independent of the stipulated damages, the amount
of the recovery would be wholly uncertain and incapable of
being clearly ascertained, except by mere conjecture. The
court will consider the damages as liquidate if they are so de-
nominated in the contract.
8. If the language of the parties evinces a clear and un-
doubted intention to fix the sum mentioned as liquidate dam-
ages in case of default of performance of some act agreed to be
done, then the court will treat the sum specified as liquidate
damages and enforce the contract if it be legal in other re-
spects.*
642. The law relating to liquidate damages has been for
years in a State of great confusion and uncertainty, for the
reason that frauds have been so frequently committed in such
contracts that the courts have endeavored, as far as possible,
to suppress the vice and protect the innocent. But where
the parties toa contract, knowing exactly their intent and
object, should be left free to make such contracts as they may
see proper and have them enforced in court. “The business
t
' Bagby v, Peddice, 16 N. Y. 469; Hamilton v. Overton, 6 Black (Ind.)
206; Smith v. Dickens, 3 B. & P. 630; Asth v. Weldon, 2 B. & P. 346;
Field on law of dam., Sec. 146; 7 Sup. Ct. U.S. 13; Foly v. McKegan,
41a. 1; Sedgwick on law of dam. 150; Robinson v. Keny, 2 Kansas 184;
Grover v. Carter, 3 Ia. 244; Mason v. Calandar, 2 Minn. 350; Daniels v.
Ward, 4 Ia. 184; Clark v. Kay, 26 Ga. 3; Wyman v. Cochran, 35 Il. 152;
Ricketts v Trustee, 29 Conn. 268; Emmon v. Von 12 Barb 366; Carpen-
ter v. Lockhart, 1 Ind. 434; 2 Ross & Peel, 346; Stuart v. White, 31 Ind.
211; Cathedral v. Salmage, 5 Feld. 551; Granalle v. Lowden, 11 Ohio st.
349; Duff v. Shocky, 11 Ind. 70; Spicer v. Hooper, 5 Ind. 365; Sainter v.
Ferguson, 7 C. & B. 716. The aim of the court should be to find out
the intention of the parties by considering the whole instrument. And
if that can be ascertained, enforce it accordingly. Tea v. Whittaker, L.
R. 8 C. P. 70; Magee v. Lovell, L. R. 9 C. & P. 107.
LIQUIDATE DAMAGES. 551
of the court is to inquire after the meaning and intent of the
parties and when that is clearly ascertained from the terms
and language used, it should be carried into effect. A court of
law is possessed of no dispensing power; it cannot inquire
whether the parties have acted wisely or rashly in respect to
the stipulations they may have thought proper to introduce
into the agreement. If they are competent to contract within
the prudential rules fixed as to parties, and there has been no
fraud, circumvention or illegality in the case, the court should
enforce the contract ”
30 L. T. N.S. P. 169; Huff v. Lawler, 45 Ind. 80; Noyes v. Phillips, 60
N. Y. 408; Legget v. Mut. Life Ins Co. of N. Y.,53 N. Y. 394; Dakins v.
Williams, 19 Wend. 447; Leay v. Lafflin, 101 Mass. 344; Hazlewuck v.
Tappen, 15 Johns 200; Mead v. Wheeler, 13 N. H. 351; Law R. 8 Ch.
App. 1022. An intention to make asum determined on as liquidate
damages payable on the breach of a minor and unimportant part of the
agreement will not be imputed in the absence of language determining
such agreement with precision. Hogland v. Sequr, 38 N. J. 230; Old-
ham v. Kerchner, 79 N. C. 106; Pearson v. Williams. 26 Wend. 630;
Powell v. Brenoun, 54 Pa. st, 329; Brown v. Maulsby, 17 Ind. 10; Chase
v. Allen, 13 Gray 42; Dunlap v. Gregor, 10 N. Y. 241; Kemble v. Farren,
6 Bing. 141; 3 M. & P. 425; Willson v. Greer, 14 Ala. 315; Young v.
White, 5 Watts (Pa.) 460.
An action was brought upon an agreement made between the plaintiff
and defendant, whereby the defendant agreed to act as principal come-
dian at the Theater Royal, Convent Garden, during the four then next
seasons, commencing October, 1828; and also to conform in all things
to the usual regulation of said Theater Royal, Convent Garden; and the
plaintiff agreed to pay the defendant £3 6s. 8d. every night on which
the theater should be opened for theatrical performances during the next
four seasons, and that the defendant should be allowed one benefit night
during each season, on certain terms therein specified. An agreement
containing a clause that if either of the parties should neglect or refuse
to fill said agreement, or any part thereof, or any stipulation therein
contained, such party should pay the other the sum of £1000, to which
sum it was thereby agreed that the damages sustained by any such omis-
sion, neglect or refusal should amount, and which sum was thereby de-
_ clared by the said parties to be liquidate and ascertained damages. The
court held that it was only a penalty. Kemble v. Farren, 6 Bing. 141.
2 Dakin v. Williams, 17 Wend. 447; Astly v. Weldon, 2 Bos & Peel.
846; Barton v. Glover.
552 LAW OF DAMAGES.
643. Ambiguity of Contracts. The questions in regard to
this subject generally grow.out of the ambiguity of the article
of agreement, or the contract between the parties. And as
courts do not look with much favor on forfeitures and penal-
3 Suit on a written agreement by which the defendant agreed that he
would, in twenty days, procure and deliver to the plaintiff a certificate
of Charles L. Trobridge and De Garma Jones, officers of the Bank of
Michigan, bearing their official signatures to the effect that there had
been shown to them (Trobridge and Jones) three notes, signed by Ham-
jlton and indorsed by John H. Hunter and R. S. Merril, for fifteen hun-
dred and eighty.seven dollars and thirty-four cents, each dated J uly I;
1840; which notes they (Trobridge and Jones) considered good, and
such as they would discount at any time when they were discounting
notes; and Hamilton stipulated that if he failed in the above undertak
ing, he would pay Overton and others five hundred dollars liquidated
damages. An assignment of a failure to procure the certificate within
the specified time and the refusal to pay the five hundred dollars. The
court rendered judgment for five hundred dollars; appeal to the Su-
preme Court. That court says: The question raised by the record is
whether the sum of $500 stipulated in the covenant to be paid for the
preach of it is in the nature of a penalty, or of damages settled and liqui-
dated by the parties. Courts have not unfrequently found difficulty in
drawing the line distinctly between penalties and liquidated damages.
The intention of the parties must govern the construction of the con-
tract in this particular as well as in all other respects, and it may be laid
down as a general rule (admitting, however, of some exception) that
when the covenant or agreement itself denominates a specific sum as a
penalty, it will be so viewed by those whose duty it is to interpret the
contract. Smith v. Dickenson, 3 B. & P 630; Astly v. Weldon, 2 B. &
P. 346; Taylor v. Sandford, 7 Wheat 13. But several cases have occurred
in which, though the parties themseives having designated the sum to
be paid on a breach of covenant as liquidated damages, it has been con-
sidered by the court as a penalty, or on the ground that from a view of
the whole contract such must have been the real meaning of the con-
tract. This is the doctrine where a specified pecuniary sum is secured
by a large sum. Astly v. Weldon, supra per Chambers; Fletcher v.
Dychi, 2 T. R. 32. The same principle is applicable to a covenant con-
taining various stipulations of different degrees of importance—some
the payment of specific sums and others sounding in uncertain dama-
ges, with general provision that a large sum shall be paid for the viola-
tion of any of the stipulations. Astly v Weldon, supra; Kemble v.
Farren, 6 Bing. 141; Davis v. Benton, B. & C. 216, Charrington v. Laing,
6 Bing. 242 But where similar provision has reference only to uncer-
LIQUIDATE DAMAGES. 553
'ties for breaches of contract, they are much inclined to apply
the rules of construction with great liberality toward the
payor in order to prevent parties from taking undue advantage
of others.’
644. The question whether a sum of money mentioned
in an agreement shall be considered as a penalty, or as dam-
ages liquidated by the parties, is always a question of con-
struction, and although the words are to be taken as proved
by the writing exclusively, yet there may be an inquiry into
the matter of the contract, the situation of the parties, the
usage to which they may be understood to refer, in order to
ascertain their intention.’
645. Importance of the Question of Construction. The ques-
tion whether the sum mentioned in the contract to secure its
fulfillment is a penalty or liquidated damages, is very fre-
tain damages and has been understandingly made, without fraud, it is a
matter of contract with which courts have no right to interfere, and
furnishes the only measure of damages. Lorne v. Press, 4 Burr 2225;
Kemble v. Farren, supra; Dakin v. Williams, 17 Wend. 447. In the
case before us there is but one covenant, and from its nature the dam-
ages for a violation of it are entirely uncertain; nor does it appear by
the record how they could be well ascertained by evidence. The con-
sideration which induced the undertaking isnot shown. We know only
what the covenant was, that it was broken, and that the parties to it
have themselves agreed upon the amount of damages to be paid for its
breach. Held, liquidate damages. Hamilton v. Overton and others, 6
Black 206.
” Foly v. McKeegan, 4 Ia. 1; Gomer v. Saltmarsh, 11 Mo. 271; Bruster
v. Egly, 13 N. H 275; Lindsey v. Anesly, 6 Ind. N. C. L. 186; Maurice
v. Body, 15 Abb. N. J. Pr. 113; Hosmer v. True, 19 Barber N. Y. 106;
Stereether v. Williams, 48 Pa. st. 450; Durst v. Swift, 11 Tex. 273. Mr.
Chief Justice Nelson, in delivering the opinion of the Supreme Court of
New York, after reviewing the authorities, says: “From the critical
examination of all the cases, and others that might be referred to, it will
be found that the business of the court in construing this clause of the
agreement as in respect to every other clause thereof, is to inquire after
the meaning and interest of the parties, and when that is clearly ascer-
tained from the terms and language, it must be carried into effect.”
554 LAW OF DAMAGES.
quently one of great importance to the parties. If it is
regarded as a penalty, the party injured by the breach can only
recover his actual damages, with some few exceptions. If as
liquidated damages the right to recover in all cases is limited
to the amount mentioned in the agreement and is conclusive
upon both parties.° i
3 In the cases of Taylor v. Sandford, argued in the Supreme Court of
the United States: The parties entered into a contract for the plaintiff
to build the defendant three houses ata stipulated price. The agree-
ment contained the following clause: ‘The said houses to be com-
pletely finished on or before the 24th day of December next, under a
penalty of one thousand dollars in case of failure.” The three houses
were not completed by the day, and the plaintiff in error claimed the
sum of one thoosand dollars as stipulated damages, and retained it out
of the money due the defendant in error. This suit was thereupon
brought, and on the trial of the cause the defendant, in the Circuit
Court claimed, to set off in this action, one thousand dollars as in the
nature of stipulated damages; but the court overruled this claim, and
decided that the said sum of one thousand dollars had been reserved in
this nature, and could not be set off in this action. * * * In general
a sum of money in gross to be paid for the nonperformance of an agree-
ment is considered as a penalty, the legal operation of which is to cover
the damages which the party in whose favor the stipulation is made may
have sustained by the breach of the contract by the opposite party. It
will not of course be considered as liquidated damages, and it will be
incumbent on the party who claims them as such, to show that they
were so considered by the contracting parties. Much strong is the in-
ference in favor of its being a penalty when it is expressly reserved as
one. The parties themselves denominate it asa penalty, and it would
require very strong evidence to authorize the court to say that their own
words do not express their own intentions. * * The counsel for the
plaintiff in error supposes that the contract furnishes a clear evidence
that the parties intend this sum as liquidated damages The circum-
stances that are annexed to the single covenant stipulating the time
when the work shall be completed, is considered as showing that it was
intended to fix the damages for the breach of that covenant. The en-
gagement that said houses shall be completely finished on or before the
24th day of December next, is as much an engagement for the manner
as for the time of finishing the work, and covers, we think, all the errors
made by the defendant in error in that agreement. The case therefore
presents the single question whether an agreement to perform certain
work by a certain time, under a certain penalty, is to be construed as
liquidating the damages which the party is to pay for the breach of his
‘ LIQUIDATE DAMAGES. 555
646. Exception to the Rule. The general rule is that a
promise'to pay a sum of money does not fall within the class
of cases to which the doctrine of liquidated damages applies,
the rate of interest allowed by law being the measure of dam-
ages for delay in the payment of money.’
647. The authorities are uniform in holding that where
a large sum is stipulated to be paid on the non-payment of a
less sum, which is certain in amount (or can be easily ascer-
tained) and made payable by the same instrument, shall be
treated as a penalty ; or where the contract contains stipula-
tions or covenants for the performance of several things of
various degrees of importance, and a sum is specified in gen-
eral terms to be paid on the breach of the contract, and even
though it be designated as liquidate damages, it will be treated
as a penalty and not as such damages.’
contract. This question seems to have been decided in the case of Smith
v. Dickinson, 3 Bass. & P. 630 The court held that the stipulation was
in the nature of a penalty, could not be allowed asaset off. Taylor v.
Sandford, 7 Wheat U. 8. 1866; Studebaker v. White, 31 Ind. 211.
® Brown v. Maulsby, 17 Ind. 10; Mead v. ‘Wheeler, 13 N. H. 351; Orr
v. Churchill, 1 H. Blackstone, 227; Sedgwick on dam., 400; Billingsly v.
Dean, 11 Ind. 331; Taylor v Sandford, 7 Wheat 13.
But the authorities are very much in conflict upon this point. The
Supreme Court of the State of New York, in the case of Dakin v. Wil-
liams held, where a note was payable on a specific day, for a certain sum,
but by its terms may be discharged by the payment of a less sum at an
early day held, that on failure to pay on the day mentioned, the plaintiff
could recover the larger sum as debt actually due. 19 Wend. 447; see
Field on law of dam , Sec. 147.
7 Daily v Litchfield, 10 Mich. 29; Bagly v. Beddie, 5 Sandford (N. Y.)
192; Bary v. Ambrose, 28 Mo. 39; Hannaman v. Breedenbock, 31 Mo,
49; Watts v. Sheppard, 2 Ala. 429; Taylor v. Sandford, 7 Wheat 13; Van
Buren v. Digges, 11 How. (U. 8.) 461; Burrage v. Crump, 3 Jones (N.
C.) L. 330; Abrams v. Kounts, 4 Ohio 214; Brown v. Maulsby, 17 Ia. 10;
see authorities cited under Section 640 of this chapter.
556 LAW OF DAMAGES.
648, The authorities in England recognize this rule. In
the case of Kemble v. Farren, which was an action on an
agreement between the plaintiff and defendant to recover
liquidate damages. By the agreement, the defendant had
engaged himself to act as the principal comedian at Convent
Garden Theater for four seasons, commencing with October,
1828, and was in all things to conform to the regulations of
tie theater. The plaintiff agreed to pay the defendant £3, 6s.
8d. every night on which the theater should be open for the
theatrical performance during the ensuing four seasons, and
that the defendant should be allowed one benefit night during
each season, on certain terms which were specified; and the
agreement contained a clause that if either of the parties
should neglect or refuse to fulfill the said agreement, or any
part thereof, or any stipulation therein contained, that sueh
party should pay to the other the sum of £1,000, to which
sum it was thereby agreed that the damages sustained by
any such omission, neglect or refusal should amount, and
which sum was thereby declared by the said parties to be
liquidate and ascertained damages, and not a penalty or penal
sum, or in the nature thereof. The breach alleged was that
the defendant refused to act during the second season. At the
trial the jury gave the plaintiff a verdict for £750. The
court of Common Pleas in commenting on the question, said:
“It is undoubtedly difficult to suppose any words more precise
or explicit than those used in the agreement, the same declar-
ing, not only affirmatively that the sum of £1,000 should be
taken as liquidated damages, but negatively, also, that it
should not be considered as a penalty, or in the nature thereof.
And if the clause had have betn limited to breaches which
were of an uncertain nature and amount, we should have
thought it would have had the effect of ascertaining the dam-
ages on any such breach at £1,000. For we see nothing ille-
gal or unreasonable in the parties, by their mutual agreement,
LIQUIDATE DAMAGES. 557
settling the amount of damages uncertain in their nature at
any sum upon which they may agree. In many cases such
an agreemen' fixes that which is almost impossible to be ac-
curately ascertained, and in all cases it saves the expense of
bringing witnesses to that point. But in the present case the
clause is not so confined. It extends to the breach of any
stipulation by either party. If, therefore, on the one hand,
the plaintiff had neglected to make a single payment of the
£3 6s. 8d. per day; or, on the other hand, the defendant had
refused to conform to any usual regulation of the theater, how-
ever minute or unimportant, it must have been contended
that the clause in question in either case would have given
the stipulated damages of £1,000. But that a very large sum
should become immediately payable in consequence of the
non-payment of a very small sum, and that the former should
not be considered as a penalty, appears to be a contradiction of
the terms, the case being precisely that in which courts of
equity have always released, and against which the courts of
law have in modern times endeavored to relieve by directing
juries to assess the real damages sustained by the breach of
the agreement.” +
649. The Same Rule is Recognized in this Country. In the
case of Carpenter v. Lockhart, the parties entered into an
16 Bingh., 141, 70.
Here there was a distinct agreement that the sum stipulated should be
liquidated and ascertained damages. There were clauses in the agree-
ment, some sounding in uncertain damages, others relating to certain
pecuniary payments. An action was brought for a breach of a clause of
an uncertain nature, and yet, for this very reason it would be absurd to
construe the sum counted in the agreement as liquidate damages.
Astly v. Weldon, 2 Bos. & Pull, 346; see also Davis v. Penton, 6 Barn.
& Cres., 216; Horner v. Flintoff,9 M. & W., 679; Edwards v. Williams,
5 Taunt, 247; Ross v. Ancell, 7 Scott, 364; 5 ‘Bing, 390; 2 Arn, 9; 3 Jur.,
316; Belts v. Burch, 3H. & N., 506; 28 Exch., 267; 1 F. & F., 485; Mayne
on dam., 66; Sedwick’s leading cases on measure of damages, 432-441;
Dock Com. ex parte, Husly k 8 ch., App. 1022.
558 LAW OF DAMAGES.
-
agreement to amicably settle a matter of difference between
them growing out of a partnership. The agreement contained .
the following stipulations: 1. The chancery suit in which
the above named injunction was granted shall be dismissed by
Lockhart. 2. The lands and effects of the firm, and also the
lands owned by Lockhart, and by the Carpenters severally, in
Union Township, Vanderburgh County, Indiana, and a tract
of land purchased of C. D. Bourne, shall be taken into settle-
ment, and shall be divided into three parts, as follows: 1.
The dry goods, etc. 2. The residue of the effects of the firm
and the aforesaid’ lands in Union Township. 8. The Bourne
tract, of which parcel the Carpenters shall take the first at,
etc., and they shall say in writing what the other two are sev-
erally worth. 38. It shall be at the option of Lockhart which
of the two said parcels, so to be valued by the Carpenters, he
will take at the valuation, but shall take one of them and
they the other. 4. The first parcel (taken by Carpenters’)
shall be applied towards the payment of a debt due them from
the firm, and the balance due them, with other debts of the
firm, to be paid by the party taking the second parcel. 6. The
party found in debt at the close of the settlem-nt shall give
notes to acceptance to A. Warner for the payment of such
indebtedness in six, twelve and eighteen months. 12. The
number of acres of Union Township land to be brought into
the settlement shall not exceed the number of acres owned by
Lockhart in said township. 13. Each of the parties to these
presents shall convey to the other by good and sufficient deed
or deeds, etc., all such real estate as such party or parties shall,
by virtue of this agreement, be entitled to have so conveyed,
so soon as the purchase money thereof shall be fully paid.
The party taking the property in the second division shall
give bond, etc., for the application of the property for the pay-
ment of the debts of the firm of said Lockhart & Co., and that
the said debt shall bé paid without unnecessary delay. 15:
LIQUIDATE DAMAGES. 59
The parties mutually covenant with each other that if either
shall fail in any particular to abide by, observe and perform
the above written agreement, or any article, clause, covenant
or promise therein contained, by or on his or their part to be
observed, kept and abided by and performed, the party so fail-
ing, etc., shall pay the other party the sum of ten thousand
dollars (and no greater or smaller sum), as and for damages
occasioned by such failure, etc. Suit by the plaintiff against
defendant for several alleged breaches of the contract, for liqui-
date damages. The court, in commenting on the question of
damages, said: “On this point we have no difficulty. The
instruction was wrong. Some of the rules for determining
whether a sum shall be considered a penalty or liquidate dam-
ages are well settled. * * One of those rules we understand
to be that, when an agreement contains various stipulations
of different degrees of importance, the damage for the breach
of some of which would be certain, and of ‘others uncertain,
and a large sum is expressed in the agreement as payable on
the breach of any of the stipulations, such sum is always to
be regarded as a penalty and not liquidate damages. This
case falls clearly within this rule.” Held, that the amount
agreed upon as damages could not be considered as liquidate
damages, but a penalty.’
31 Ind., 434; see also Studebaker v. White, 31 Ind., 211; Duffy v.
Shockey, 11 Ind., 70; Hamilton v. Overton, et al.,6 Black., 206. The
same principle is applicable to covenants containing various stipulations
of different degrees of importance, some for the payment of a specific
sum, and other sounding in uncertain damages with a general provision
that a large sum shall be paid for a violation of any of its stipulations, it
is always held as a penalty.
Hamilton v. Overton, et al., supra; Foley v. McKeegan. 4 Ia, 1; Jam-
ison v. Grey, 29, Ia., 587; Hise v. Foster, 17 Ja., 23; Baird v. Tolliver, 6
Humph. 186; Lord v. Gaddis, 9 Iowa, 265; Hoagland y. Senger, 3 N. J.,
230; Taylor v. Sanford, 7 Wheat, (U.8.), 13; Bagley v. Peddie, 16 New
York, 469.
560 LAW OF DAMAGES.
650. Cases in which the Stipulated Amount Hax Been Allowed
asa Penalty in England. In England the decisions are harmo-~
nious in holding that where the amount of recovery is wholly
incapable of being estimated, except by mere conjecture, the
court will consider the stipulated amou it to be paid on the
breach of the whole, or any of the provisions of the contract,
as liquidate damages (and especially where it is clearly ex-
pressed to be such) and not as a penalty.’
‘
651. In the case of Galesuett v. Strutt, which was a suit
on an indenture for a dissolution of a co-partnership between
the plaintiff and defendant as attorneys and solicitors, Strutt
promised and agreed that he would not, at any time or
times thereafter, within the next seven years, directly or indi-
rectly either by himself or in co-partnership with anoth-
er, or others, carry on the said practice, profession or busi-
ness of an attorney or solicitor within the distance of
fifty miles from —————, nor interfere with, solicit or in-
fluense the clients of the late co-partnership. The sim
of £1,000 was fixed as liquidate damages. Action commenced
—breach assigned: practicing attorney within fifty miles.
Parker B.,in delivering the opinion of the court, said: ‘|
take it to be clear that upon the true construction of this
covenant, the defendant would not be bound to pay more than
,
™ Mayne on Dam.. 67; Alkyns v. Kenner, + Exch., 776; Green v. Price,
13 Mees & Price, Wells 695; 14 L. J. Exch., 225; Price v. Green, 16 M. &
W., 346; 16 L. J. Dxch. 108-9; Sainter +. Ferguson, 62 Eng. Com., 716;
Ranulaon v. Clark, 14 Mccs ¥ Wells, 716; Crisdee vy. Bolton, 3 Car & P.
240, Atkins v. Krimer, 4 Ixch., 776; Lowe v. Peers, + Burr, 2225; Fletch
er v. Dyche, 2 T. R.. 32; Ruby v. Jones, 1 Bing, 302; 8 Moore, 244.
But where the rule in the construction of these contracts is that if the
agreement consists of one or more stipulation the breach of which cannot
be measured, then the contract must be taken to have meant that thesum
agreed upon was to be liquidated damages and nota penalty. Mayne on
Dam., 67; Atkins v. Kinner, supra.
LIQUIDATE DAMAGES. 561
£1,000, that is in case he should have violated either of those
two or three matters mentioned in the covenant. These mat-
ters,are each of them incapable of exact estimation. It can
not be said what damages a person must sustain by another
setting up in business within a limited period of time, or dis-
tance, nor how much he may be injured by the loss of one of
his clients. The loss may be either great or small, and there-
fore, in order to avoid all dispute the parties are content to fix
a certain sum, namely, the sum they have mentioned in ex-
pressed terms in their agreement. Now it is perfectly com-
petent for parties to make a stipulation to pay a fixed sum for
a breach of a covenant, the damages arising from which it is
extremely difficult to ascertain, and I think it is not an unrea-
sonable stipulation which the defendant has made, that he
should pay £1,000 upon the event of either matters mentioned
in this agreement.
652. This doctrine is generally approved in this country.
In the case of Studybaker et al. v. White, which was an action
brought for damages for the breach of the conditions of a bond.
The defendant agreed with the plaintiff to sell no more spirit-
uous or malt liquors, or wine, within the county of Wells,
State of Indiana, after the 4th day of March, 1859, nor cause
the same to be sold within the said county, either directly or
indirectly, after the said time specified. And he further
bound himself to neither manufacture or obtain any spirituous
or malt liquors, or wine, or cause to be sold in said county
aforesaid, by himself or any other person, either directly or
indirectly, after the 4th day of March aforesaid.. And he fur-
ther bound himself to settle certain obligations calling for
liquor, payable to Joseph Richy, of the sum of $177.57; but
in no case was liquor to be brought to the town of Bluffton,
21 Exch., 658; see Atkins v. Kinner, 4 Exch., 766.
562 * LAW OF DAMAGES.
county of Wells. And he agreed further to use his influence
to prevent any person or persons from bringing any of the
aforesaid liquors to the aforesaid town with the intentign of
selling within the town aforesaid. The sum named in the
bond was one thousand dollars. After commenting on the
question of damages and reviewing the authorities at some
length, the court said: “The sum named in this case is to be
regarded as liquidate damages, and any violation within the
plain intent and purpose of the contract, authorizes such
recovery.” *
653. Bagley v. Peddie et al. In this case one of the defend-
ants, Charles B. Peddie, agreed with the plaintiff, who was the
manufacturer of gold pens, to serve him for four years; and
that he would not disclose any of the secrets of the business,
or any improvements or discoveries or process employed against
fraud, etc. Thomas B. Peddie joined with the employe in
executing a bond to the plaintiff in the sum of $3,000 as
liquidated damages, and not by way of penalty or otherwise.
And it was further stipulated that if the employe should fail
to serve the employer as per agreement, or violate any of the
covenants in said agreement, then the above bound obligors.
were to pay to the plaintiff the above sum of $3,000 as liquid-
ated damages. Action was brought for a breach. The court,
in commenting on the question of damages, said: “The prin-
cipal question to be settled in this case is whether the parties
have so contracted as to have fixed the amount of damages to
*31 Ind. 211; Duffy v. Shocky, 11 Ind. 472; Catheal v. Talmage, 5 Seld.
551; Granelli v. Lowden, 11 Ohio st. 349; Sedgwick on dam. (4th ed.)
472; Hamellor v. Overton, 6 Black 206; Lang v. Werk, 2 Ohio st. 520;
Pierce v. Fuller, 8 Mass 222; Dakin v. Williams, 17 Wend. 447; Jemi-
son v. Gray, 29 Ia. 537; Hise v. Foster, 17 Ta. 23; Harbrouck v. Tappen,
15 John 200; Mead v. Wheeler, 13 N. H. 351; Hardee v. Howard, 33 Ga.
533; Sutton v. Howard, Ia. 5386.
N
LIQUIDATE DAMAGES. 563
be recovered of the defendant in case of the non-performance
of Charles B. Peddie. Although the courts have uniformly
conceded to parties the right to fix the amount of damages in
advance of the breach of the contract, and at any sum, how-
ever disproportioned to the real damages they shall see fit, arid
have likewise conceded that in question of intention to be de-
rived from the scope and the tenor of the agreement. Yet
when the judicial mind has acted upon this class of cases, it
isevident how repugnant it has been to enforce them accord-
ing to the plain, expressed language of the contracting parties.
Hence have sprung up a series of artificial rules for construc-
tion peculiar to contracts of this character.” After comment-
ing at great length on the rules of construction, the court held
that ‘The damages to result from a breach of any of the stip-
ulations of the agreement being uncertain and conjectural, it
was held that the sum of $3,000 could be recovered as liquidate
damages.®
6 16N. Y. 469; see Sainler v. Ferguson, 7 C. & B. 716.
CHAPTER XXXVI
OFFICIAL BONDS.
StTaTuUTORY AND Common Law Bonnps. OFFiIcrIAL Bonps. GEN-
ERAL RULE OF DAMAGES. GENERAL LIMITED BY THE PENAL-
ty. ATTACHMENT BONDS. ARBITRATION BONDS, NE EXAT
BONDS. INJUNCTION BONDS. DELIVERY BONDS. APPEAL
BONDS. INDEMNIFYING BONDS. REPLEVIN BONDS. RECEIPT
BoNDs. SEcurtry. MInisteRIAL Orrices. Remote Dam
AGES. LIQuoR BONDS.
654. Official Bonds. In most, if not all the States, it is
provided by statutes for the election of a number of State,
county and township officers, and fixing their liabilities and
duties. And it is generally provided that such officers shall
qualify and give bond in a specified amount for the faithful
discharge of their official duties. These bonds are given for
the protection of the public and private individuals who tran-
sact business with them from loss. And it is now pretty well
settled that they are the insurers of all money that may come
into their hands or is entrusted to their care2 And when one
is sued on his official bond for a failure to account for money
BONDS. 565
entrusted to his official care, he cannot exonerate himself from
liability by showing that the money was stolen from him with-
out negligence or fault on his part.'
655. The Damages. As a general rule, in penal bonds, the
recovery will be limited to the actual injury or loss sustained
by the plaintiff, and in some cases interest;* And that the
penalty named in the bond will be considered as security and
not as liquidate damages.°
656. The Extent of the Plaintiff’s Recovery. As a general
rule, adopted in all the States, the damages cannot exceed the
penalty of the bond. The contract fixes that amount as the
ultimate responsibility of the obligators, and no greater amount
than that can be recovered in any event on official bonds."
But st seems that where the loss sustained by the plaintiff is
equal or greater than the penalty, and the obligors fail to pay
‘
3 Halbert, ex rel., v. the Board of Commissioners of Martin County,
22 Ind., 125. ~
4 Halbert v. the State, ex rel., Board of Coms. of Martin Co., 22 Ind.,
125; Muzzy v. Shattuch, 1 Denio, 233; Inhab. of Hancock v. Hazzard,
12 Cush., 512; U.S. v. Pres., 3 Howe, 578; Commenwealth v. Conely, 3
Pa. st. Rep., 372; State of Ohio v. Harper, 6 Ohio, 607; Warren v. Steele,
10 Ala., 374; Freeman y. The People of Illinois, 54 Illinois, 153; State of
Missouri v. Sandusky, 46 Mo., 317.
6 Davis v. Gillett, 52 N. H., 126.
Interest on the penalty is now generally allowed, on the ground that
when there is a breach of the condition of a penal bond, the penalty be-
comes, in law, 4 debt due, and the obligors can discharge themselves
from liability on the bond when the liability equals or exceeds the penal-
ty. Ifthe payment of the penalty alone, and if it be not paid at the
time of the breach, then it should bear interest until paid. Hughes v.
Wickliff, 11 B. Mon., 202; Carter v. Thorn, 18 B. Mon. Roe, 618; Brain-
ard v. Jones, 13 N. J., 35; Carter v. Carter, 4 Day 30.
’ Davis v. Gillett, 52 N. H., 126; Walker v. Foard, 5 Black, 392; White
y. Sealy, Dougl., 49; Brangrive v. Perrot, 2 W. B., 1190; Welde v. Clark-
son, 6 T. R., 303; Mockworth v. Thomas, 5 U. S., 329; Clark v. Seton, 6
566 LAW OF DAMAGES.
his claim when the breach occurs, the penalty in law begomes
a debt due, and the obligors can discharge themselves by pay-
ment of the penalty alone, and if it be not paid at the time
of the breach, it should bear interest until paid.’
657. But there are authorities which hold that the plain-
tiff in an action on covenants or stipulations of a bond for the
sale and conveyance of real estate may recover damages in
excess of the penalty. They measure the damages by the
good or bad faith of the parties. If the vendor entered into
the contract in good faith, and is prevented from making the
conveyance by an unforeseen cause, over which he had no con-
trol, the vendee can recover the money which he has paid with
interest and nominal damages; but if the vendor is in the
fault and did know, or should have known, that he had no
title and would be unable to make the conveyance according
to contract, or if, having title he refuses to convey the plain-
tiff may recover substantial damages, such as, the increased
value of the land between the making of the bond and the
breach of it.?
Ves., 411; Hellen v. Ardly, 3 Car. & Payne, 12; Hughes v. Wyne, 1
Mylne & Keene, 20. There are some cases that hold that the principal
can be held on the bond for any amount over the penalty, but that the
security cannot.
1 If the damages exceed the penalty, the common law rule governs,
and the penalty is the debt, That is all that the obligor in any event
has bound himself, and all of course that can be recovered, except the
costs of the suit. State ex. rel. Walker v. Ford, 5 Black 392; Hughes v.
Wickliff, 11 B. Mon. 202; Carter v. Thorn, 18 B. Mon. 613; Branard v.
Jones, 18 N. Y. 35; Carter v. Carter, 4 Day 30; State of Missouri v. San-
dusky, 46 Mo. 377; McCoy v. Elder, 2 Black 183; Davis et al v. State ex
rel. Board of Commis. of Barth. Co., 44 Ind. 138.
? Foly v. McCeegan, 4 Ia. 1; Swan v. Steel, 5 Ia. 352; Harrison v.
Wright, 13 East. 843; Swan v. Steel, 10 Ia. 374; Martin v. Taylor, 1 Wash.
Cc. 0.1. 2
\
BONDS. 567
658. Damages under Statute on Suit or Attachment Bond. In
most of the States they have statutory provisions governing
the suing out of writs of attachment; and in most, if
not all, the plaintiff is required to give bond, with a penalty
and surety for the faithful prosecution of his proceeding in at-
tachment, and to pay all damages and costs that the defendant
may sustain if such preceeding shall prove wrongful and op-
pressive. Action on an attachment bond will not bar the
defendant of his right of action for malicious prosecution, but
he will be confined in his action on this bond to such injuries
as he may sustain by reason of such a’tachment proceeding.
It has been frequently held by the court of last resort of this
country that the giving of the bond in the attachment pro-
ceedings does not effect the defendant’s remedy at common law
for malicious prosecution.’
659. The Damages. The plaintiff’s measure of damages
will be, in an action on attachment bonds, the actual loss that
he has sustained. “On general principles it must be the
natural proximate legal result or consequence of the wrongful
act. Remote or speculative damages, such for instance as re-
sult from injury to credit, business character or feelings can
not be recovered. Actual damages may be properly compre-
hended under two heads: 1. Expense and losses by the plain-
tiff in making his defense to the attachment. proceedings. 2.
Loss occasioned by his being deprived of the use of his prop-
erty during the pendency of the attachment, or by the illegal
sale of it, or by injury thereto or loss or destruction thereof.
For losses and trouble of this description, the plaintiff should
be liberally remunerated.” Under the first head the plaintiff
will be allowed all expense incurred in procuring evidence and
1 Sanders v. Hughes, 2 Beauch. 495; Donnell v. Jones, 13 Ala 490;
Smith y. Story, 4 Humphreys 169.
568 LAW OF DAMAGES.
obtaining his testimony on the trial, and all costs of suit in
all the courts to which it may be taken, and fees paid attor-
neys for services in the attachment suit, but not in the suit
for damages.’
The rule of damages under the-second head is variously
laid down. “In New York it has been held that the plaintiff
may recover such damages as a jury may think he has sus-
tained by the wrongful seizure and detention of the property.”
Tf it was taken out of his possession he may recover its value;
if siezed and left in his possession, to such damages as may be
awarded for the unlawful intermeddling with his property.”
But the same court afterwards held that no more than nominal
damages can be recovered where in the attachment the defend-
ant is not dispossessed.* If the plaintiff in the attachment
proceedings fails to sustain his proceedings in attachment,
although he succeeds in his action, he is liable on his bond.
If he fails in his action and the attachment, he is liable in
damages on his bond, or in other words, if the proceedings in
attachment are wrongful and oppressive, that gives the attach-
2 Wilson et al v. Root et al, 43 Ind. 489; Sedgwick on the measure of
damages, 543; Drake on attach., sec. 175; Manes v. Price, 2 Black 457;
Hosham v. Hosham, 8 Black 258; Campbell vy. Chamberlin, 10 Ia. 337;
Hayden v. Sample, 10 Mu. 215; Seay v. Greenwood, 21 Ala. 491.
Duneg v- Humphries, 24 Wend. 31. :
® Grate v. Gillespie, 24 Wend. 386; Raner v. Webster, 3 Ia. 502; Plumb
v. Woodmansee, 34 Ia. 116; Bennet v. Brown, 31 Barber 158; 20 N. Y.
99; Silsby v. Lucas, 5 Ill. 479; Collins v. Sinclair, 51 Barb. 328; Myers v.
Farrall, 47 Miss. 281; Field on dam. p. 440, Sec. 550. It has been held
in Iowa that the plaintiff in a suit on an attachment bond may recover
exemplary damages, if he can show that the defendant sued out the
attachment maliciously. Field on law of damages, p 438, Sec. 559,
BONDS. 569
ment defendant a good cause of action, whether the plaintiff
in the attachment has a good cause of action against the
attachment defendant or not.’
But injuries to credit, character or business are too remote,
and cannot be recovered. Generally, the plaintiff may re-
cover his expenses and loss in making his defense to the attach-
ment proceedings, the loss arising from being deprived of
possession and use of his property during the attachment
proceedings, or by illegal sale of it, or by injury therto, or loss
or destruction thereof.
Also such damages as he may sustain in the destruction
of business, where it is the natural result of the trespass.°
3 Harper et al v. Keys, 43 Ind. 220.
Where the attachment was wrongfully sued out and there was not
probable cause for believing the grounds upon which the game was
issued upon were true, the plaintiff, in an action on the bond, may re-
cover reasonable attorney fees, and the destruction of business by the
taking of goods may be a proper element of damages when the destruc-
tion or loss is the natural result of the trespass. And where the plain-
tiff was prevented, by reason of his property being attached,
from performing a contract previously made, and material prepared to
be used for that purpose, is depreciated in value, this is a proper ele—
ment of damages. Carpenter v. Stevenson, 6 Bush. 259; Field on dam-
ages, 441.@
4 State Bank v. Morrison, 13 Ia. 136; Stadler Bros. & Co. v. Parmalee
& Watts, 10 Ia. 26; Ripley v. Mosby, 57 Md. 76. In Illinois it has been
held that an injury to credit and business are proper elements of dam-
ages. 656 Ill. 674; McCullough v. Watson, 11 Ala. 492; Keery v. J ones,
7 Ala 622; Seay v. Greenwood, 21 Ala. 493; Spring v. McGee, Id. 417.
In Iowa it has been held that the plaintiff in an action on the attach-
ment bond where the suing out has been wrongful and oppressive, may
recover expense in defending the attachment suit, loss sustained by be-
ing deprived of the property attached, for injury occasioned by its de-
preciation in value, or entire loss. And that where the suing of the
attachment was wilfully wrong, exemplary damages might be allowed,
Campbell v. Chamberlin, 10 Ia. 337.
6 Carpenter v. Stevenson, 6 Bush. (Ky.) 259. The damages recoverable
570 LAW OF DAMAGES.
660. Mitigating Circumstances. The defendant may show in
mitigation that he was non-suited in the original attachment
suit, and that the property he had at that time attached he
has since re-attached in a subsequent action by him, which
had been prosecuted to judgment under which the property
was sold.’ But where the original taking is absolute trespass,
however, without color of legal right, it is thought that such
facts would not be admissible in mitigation of damages in
suits on the attachment bond.’
661. Arbitration. The common law looks with great favor
upon the efforts of men to settle their differences in a peacea-
ble, friendly way. They make such settlement themselves, or
they may do it through the intervention of others, and then
it is called an arbitration. The common law holds these set-
tlements as binding on the parties, unless fraud or mistake can
be shown; and it is a matter of no consequence whether the
settlement is made between the parties themselves or by
friends mutually chosen by them, the effect will be precisely
the same, for a rule of law is that what a man does by another
he does by himself.’ The persons chosen by them will be con-
sidered their agents, called in law arbitrators. Having chosen
their arbitrators and clothed them with plenary power,
and authorized them to settle the matter of difference between
them, the acts of these agents will bind their principals accord-
ing to the well recognized rules of the law of principal and
agent. The learned Blackstone, many years ago, in speaking
in regard to arbitrators said, ‘“‘ Experience having shown the
on an attachment bond should be the deprivation of the use of property.
They should be reasonable, certain and the natural and proximate con-
sequence of the breach. Sedgwick on measure of dam., 489.
7 Early v. Spooner, 3 Denio 246.
1 Sedgwick on measure of dam., 490 notes; Field on law of dam. 441-2,
? McDonald’s Treatise, 303; 2 Tedds 877; 3 D. & R. 184.
BONDS. 571
great use of these peaceable and domestic tribunals, especially
in settling matters of account and other mercantile transac-
tions which are difficult and almost impossible to adjust on a
trial at law. The courts of justice are strongly inclincd to
favor such mode of making peace between persons who disa-
gree as to their mutual dealings.”? And the same remarks
apply equally as forcibly to matters of torts unconnected with
the contract. This method of settling differences and difficul-
ties commends itself to every lover of law and order. And it
is a matter to be much regretted that this method of adjusting
difficulties among neighbors is not more frequently resorted to
than it is. The parties may by verbal agreement submit their
disputed points to the arbitrators, or they may reduce it to
writing.‘ /
662. Bonds Given. It is not unfrequent for the parties to
a common law arbitration to enter into a mutual bond to abide
by the arbitration, and to pay all costs that may be awarded
against them. And in many of the States they have a muni-
cipal law which provides for what is generally termed a statu-
tory arbitration. In this class of arbitrations the parties are
generally required to enter into.bond to abide by and pay the
award of the arbitrators. In case of a failure to pay and breach
of the bond, suit is brought on either a common law or statu-
tory arbitration bond; the measure of damages will be the
amount of the award with legal interest from the time of its
rendition.®
663. Ne Exat. On complaint filed in a court of chancery,
showing that the defendant is indebted to the plaintiff in a
” 3 Blackstone 17.
3 Shayer v. Bash et al, 57 Ind. 394.
* Miller v. Goodwin, 29 Ind. 46. Attorneys’ fees cannot be recovered
in suit on bond, Miller y. Hays, 26 Ind. 380.
572 LAW OF DAMAGES.
specified sum, and that the defendant designed going soon to
parts without the State to the damage of the plaintiff, the
court will order a writ reciting the facts to be issued to the
sheriff, or other officer, commanding him to arrest the defend-
ant and cause him to give bail in a sum sufficient to cover the
plaintiff’s claim; and if he fail or refuse to procure such bail,
then to commit him to prison. This writ is now used in most
of the States to secure bail or security on notes not yet due,
or where a party is about to leave the State without making
provision for the payment of the same.’ But where the surety
is given, the amount of the bond is generally fixed sufficient
to cover the debt, and where this is the case the measure of
damages on breach of the bond is the amount of the bond.
But if the amount of the bond is greater than the debt, the
measure of damages will be the indebtedness.'
664. Injunction Bond. In most, if not all of the States,
the granting of restraining orders and injunctions is regulated
by municipal lawor statute. It is generally provided by these
statutes that the party praying for the injunction shall enter
into bond, with security that he will pay the opposite party
or the defendant all damages and costs which may accrue by
reason of the injunction. Asa general rule the plaintiff, in
case of a suit on the bond, may recover his ordinary and actual
damages resulting from the injunction, and reasonable attor-
ney’s fees, paid or incurred, in procuring a dissolution of the
injunction.’
12 Kent’s Com. 32; 1 Clark 551; Beams ne exat 13; Harris v. Hardy,
393. :
* Field on damages, 442; Andrews v. Glenville Woolen Co.,50 N. Y.
282; Corcoran v. Judson, 24 N. Y. 106; Winship v. Clendenning, 24 Ind.
439; Brehens v. McKenzie, 23 Ia. 333, Edwards v. Bodine, 11 Paige 224;
Coots v. Coots, 1 Duer 664; Aldrich v. Reynolds, 1 Barb. Ch. 613; Thaire
BONDS. 573
665. The right to recover attorney’s fees where the prayer
‘for an injunction is only auxiliary to another suit, is limited
to the defense in procuring the dissolution of the injunction,
and cannot be recovered for service in the entire action* An
_action will not lie on an injunction bond until the dissolution
of the restraining order.’ Where the plaintiff had the right
to possession of some real property under a coptract of pur-
chase, was enjoined at the suit of the defendant from en-
tering upon the land in a suit on the bond for the breach, the
court held that the plaintiff might recover for any injury to
the possession, or to the land, caused by the injunction.®
Where the plaintiff is enjoined from issuing an execution and
is prevented from collectiing his judgment in case of a dis-
solution of the injunction, the usual rule is to allow as damages
the amount due thereon including interest and costs’ The
plaintiff can only recover such damages as are the direct, na-
t
v. Quan Wan, 3 Cal. 216; Prader v. Grimes, 28 Cal. 511; Garrett v. Lo-
gan, 19 Ala. 344; Derry Bank v. Heath, 45 N. H. 524; Ryan v. Anderson,
25 Ill. 872; Collins v. Sinclair, 51 Ill. 328; McCrea v. Brown, 12 La, An.
181; Brown v. Jones, 5 Nev. 374; Mesner v. Bullard, 43 Ill. 474; Fox Vv.
Mountjoy, 6 Muf. (Va ) 36.
* Langworthy v. McKelney, 25 Ia. 470.
5 Thompson v. McNair, 64 N. C. 448: Leavitt v. Dobsey, 9 Abb. P. (N.
S.) 373; Sturgis v. Knapp, 33 Vt. 486; Comdore y. Martin, 17 Mo 41;
High on inj. 557.
8. Winship v. Cledenning, 24 Ind. 439. In an action on a bond where
the plaintiff had been wrongfully restrained in the spring of the year
from taking possession of a farm, and was prevented by reason thereof
from cultivating a crop, the court held that he was entitled to recover
for the whole loss sustained by being kept out of possession, including
the subsequent crop. Edwards v. Edwards, 31 Ill. 474
7 Southlan v. Crawford, 2 J. J. Mar. 370; Washington v. Parkes, 6
Ligh. 581; Gist v. McGuire, 4 Har. & J. 9; Wallis v. Dilley, 7,Md. 237,
*
574 LAW OF DAMAGES.
\
tural and proximate consequence and result of the injunction,
and remote and speculative damages are never allowed.’
666. Consequential Damages. It may be laid down as a gen-
eral rule in the absence of statutes limiting the liabilities, and
where there is no malice shown, that the plaintiff is entitled
to recover full compensation for all loss sustained. The court
or jury in estimating his losses should take into consideration
loss or depreciation in the value of the goods restrained from
sale; damages by delay in collection of money, counsel fees,
expense incurred in injunction suit, rent of farm, the loss of
crop, destruction of timber, coal, etc. In general, every injury
resulting directly from the injunction, should be considered in
assessing the plaintiff’s damages.”
667. Delivery Bond. In many of the States it is provided
by law that where a sheriff or constable levies an execution
upon personal property the judgment defendant may have a
return of the property, provided he will enter into a bond, with
security, to be approved by the officer, to the effect that he
will safely keep the property and deliver it to the officer at the
time and place named in the bond, to be sold according to law,
’ Brown v. Jones, 5 Nev. 374; Collins v. Sinclair, 51 Ill. 328; Stewart
v. State, 20 Md. 97; Morgan v. Negley, 53 Pa. st. 158; Burgen v. Share
14 B. Mon. 497; Kennedy v. Hammond, 16 Mo. 341.
* Brown v. Tyler, 34 Tex. 168; Wintzly v. Robinson, 23 La. An. 451;
Moulton y. Richardson, 49 N H 75; Allen v. Brown, 5 Lansing (N. Y.)
511; Trustees Tamaroa v. Southern Ill. ete. reviews, 54 Ill. 334; Pierce v:
Atly, 4 W. Va. 22; Collins v. Sinclair, 51 Ill. 328; Silsbe v. Lucas, 53 Ill.
453; Hamilton v. Steel, 32 Md. 348.
Where a mortgagor obtained an injunction to prevent the mortgagee
from selling a tract of land on foreclosure, in a suit on the bond, the
court held that the plaintiff could recover damages caused by the de-
fendant cutting timber on the land during the time the injunction was
in force, if the security had been thereby impaired. 1 Barb. ch. 613.
.
BONDS. 575
or that the sheriff shall receive its appraised value, or in case the
property has not been appraised, then ifs real value. Ona
breach and failure to deliver or pay the value of the property,
the measure of damages is the amount of damages sustained,
not exceeding the penalty... Where the value of the property
levied on exceeds the amount of the judgment and costs, or
the amount of the execution in the hands of the officer, the
measure of damages should be the amount of the execution at
the time of the commencement of the suit on the bond, or the
amount of the judgment, with legal interests and costs."
668. Appeal Bond. In all of the States appeals are au-
thorized from the inferior to the superior courts. And as a
general rule the appellant, in order to get his cause into the
higher court and have a stay of further proceedings below, is
required to give bond, with security, that he will prosecute
his appeal without delay, and pay the judgment that may be
rendered in the court above. The law generally makes it the
duty of the Judge or some officer of the court to fix the pen-
alty and approve the bonds. But as the bond is for the sole
benefit of the appellee, and the law requiring the Judge or
some officer of the court to approve the bond, makes him an
arbiter to'decide between the contending parties where they
might not be able to agree as to what would be a good bond.
But this does not deprive the litigant parties of the right to
mutually agree upon the sufficiency of the bond.’
669. Conditions of the Bond. There are two stipulations in
almost every appeal bond: 1. To prosecute with effect and
1 Field on the law of damages, 445-6; McCoy v. Elder, 2 Black (Ind.)
188; Mitchell v. Cenbro, 3 Black 259. No more can be recovered in suit
on bond with a penalty than the penalty. 5 Black 392; Paine 662; 2
McLane 581; 4 Day (Conn.) 30.
2 Jones v. Doneberger, 23 Ind. 74; Ham v. Greves, 41 Ind. 531.
576 LAW OF DAMAGES.
without delay. 2. That the appellant will pay the judgment
and costs that may be rendered against him in the appellate
court. By the failure to perform either stipulation the condi-
tion is broken and the bond forfeited? The measure of dam-
ages in case of a breach will be the amount of actual loss
sustained, not exceeding the penalty.’
But if, after an appeal has been taken and bond filed, the
appellant dismisses his appeal, though the dismissal of the
appeal has the effect to affirm the judgment below, yet it does
not make it a part of the judgmeut of the appellate court.
Unless the plaintiff can show in such cases that he has been
damaged by the delay of the defendant in the prosecution of
his appeal, he can only recover the judgment for costs in the
appellative court.°
670. Indemnifying Bonds Defined. An indemnifying bond
is a bond given by one person for the purpose of securing an-
other against loss or injury, or to save him harmless from cer-
tain contemplative acts. These bonds are frequently taken by
sheriffs and constables when they are requested by interested
parties to bring an execution upon property, the title of which
is in dispute. If the bond is one of indemnity merely, the
obligee can not maintain an action thereon until he has sus-
tained absolute damage.’ But if it be a guaranty, he can
maintain an action where the thing guaranteed against is
done, whether he has suffered actual damage or not.
? Reeves v. Andrews, 7 Ind. 208.
* Field on the law of damages, 445-6; Railesbeck v. Greve, 57 Ind. 72.
5 Railesbeck v. Greves, 57 Ind. 72. To prosecute a suit with effect
means that it shall be prosecuted successfully to final judgment. 5
Black 533; Watson v. Husson, 1 Duer 242; Abb. Pl. (N. Y.) 219; Kutz
enger v. Reynolds, 11 Ind. 545. Failure to prosecute the appeal on
account of appellant’s death, is a breach of the bond. 8 Black 404.
* Redfield v. Height, 27 Conn. 31; Ham v. Hill, 29 Mo. 275; Sedgwick
BONDS. 577
671. The Measure of Damages. ‘The measure of damages
where the instrument deviates in the least from a simple con-
tract to indemnify against damages, “even where the indemn-
ity is the sole object of the contract, and when in consequence
of the primary liability of the other person actual loss may be
sustained, the decisions of our courts, although by no means
uniform, have gradually inclined towards fixing the rule of
damages at actual compensation, and’it may now be considered
as a general rule both in this country and in England.’
672. The Supreme Court of New Hampshire in the case
of Holt v. Holcombe, held, in a case where a sheriff had ap-
pointed a deputy and taken a bond indemnifying himself from
all loss, damages and costs on account of the acts and neglects
of the deputy, that in case of a breach the sheriff could recov-
er as damages in addition to the sum paid by him or his
sureties on his official bond, and interest thereon, and all other
reasonable expenses incurred by him in and about the defense
of the suit in which the full judgments were rendered, includ-
ing counsel fees and a reasonable compensation for his personal
service; and in the suit on the bond the same expenses and
compensation for services beyond the taxable costs, but not the
cost or expense incurred in 4 suit upon his official bond brought
to enforce payment of such judgment.’
673. So in New York, in an action by the sheriff against
the sureties of his deputy, to recover damages for the neglect
_of the deputy to levy an execution in consequence of which
q
on meas. of dam., 368; Haydon v. Cabot, 17 Mass. 169; 2 Kem. 296;
Powell v. Smith, 8 Johns 249; Weller v. Farner, 15 Minn. 461.
2 Gilbert v. Wiman, 1 Comst. 550; Deval v. McIntosh, 23 Ind. 529;
Wilson v. Stilwell, 9 Ohio st. 467; Loosemore v. Radford, 9 Meeson &
Wilsby 657; Weddle v. Stone, 12 Ind. 625.
3 32 N. H. 185; 3 Westesvelt v. Smith, 2 Duer 449.
578 LAW OF DAMAGES.
the execution creditor had recovered a judgment against the
sheriff; the court held that the sheriff could recover the
amount of the judgment and the reasonable expense in de-
fending the suit against himself. The Supreme Court of the
United States held, in the case of Wicker v. Happock, where
the defendant agreed that if the plaintiff would prosecute a
claim against a third party, and obtain a judgment and levy
on property, he, the obligee, would bid it off for whatever the
judgment and costs might be. This he did not do and the
property was knocked down to the plaintiff for a nominal
sum. Suit was brought for a breach of the agreement; that
the defendant was liable for the full amount of the judgment,
with interest and costs.*
674. Replevin Bonds. As has already been said, in most
of the States the old action of replevin as it existed at com-
mon law has been abolished, and in lieu of it there has been
substituted what has generally been called an action to recover
personal property. Under these statutory provisions the plain-
tiff must, when the property is returned to him, enter into
bond to indemnify the defendant against all losses if he fails
to prosecute his action without delay, and to return the prop-
erty, if return be demanded, to the defendant. In case the
plaintiff fails to return the property, if a return be awarded
in the replevin suit, there is at once a breach of the condition
of the bond and the obligee may forthwith bring suit on the
bond. The judgment establishes te liability of the obligor.'
46 Wall 94; see 9 Ohio st. 467; 12 Ind. 625; 23 Ind. 529. In an action
‘on an indemnity bond. if the plaintiff states no special damages in his
complaint, he is confined in his recovery to such only as arise from the
breach, and then such only as are proximate and the fair, legal and
natural result of the act complained of. Hallock v. Belcher, 42 Barb.
199.
1 Levering v. Lomme, 22 Wall 208.
BONDS. 579
‘
675. The Measure of Damages. The measure of damages
in cases of this character will depend toa very great extent
on the circumstances surrounding each case, the value of the
property and the interest of the party. If there as been a
final trial and the rights of the defendant to the possession
and right of property settled and fixed in the replevin suit,
then ina suit on the bond he may recover the value of the
property at the trial.?- But suppose the property has risen in
value, from a natural cause, since the commencement of the
suit or action, shall the plaintiff have judgment for the in-
crease? Reason, as well as the law would say that he should.’
But where the enhanced value has been brought about by the
labor and expense of the obligor on the bond, while the prop-
erty was in his possession, the plaintiff can only recover the
value of the ‘property at the time of the service of the writ
and the taking of the property by the officer." The determina-
tion of the replevin may or may not be conclusive of the right
of property according to the circumstances of the case. But
where the right of property is put in issue and decided on, it
is then res adjudicata, and cannot on general principles be in-
quired into in a suit between the same parties. If, however,
the right has not been tried, it remains an open question for
the determination of the court in a suit on the bond for dam-
ages.° And in an action by the obligee against the obligor on
the bond, if it appears that the title of the property has not
been determined in the replevin suit, and that the title of the
property and right of possession is in a person other than the
obligee, he can only recover nominal damages. And this rule
2 Schrader v. Wolfland, 21 Ind. 238; Walls v. Johnson, 16 Ind. 374;
30 Wis. 570; 24 Wis. 299.
* Frazer v. Fredrick, 4 Zab. (NV. J.) 162.
4 Single v. Schrader, 30 Wis. 570; Hugerford vy. Redford, 29 Wis. 345;
Hedrick v. Young, 54 Pa 176.
580 LAW OF DAMAGES.
holds good even if the court orders a return of the property to
the plaintiff’
There has been some controversy over the question of the
responsibility of the obligor who has given bond for the deliv-
ery of live animals, and fails to do so on account of the death
of the property while it was in his hands. But it is an
old, well settled principle of the common law that if a bond
or obligation, possible of performance at the time of execution, becomes
impossible by the act of God, or of law, or of the obligee himself, the
obligor will be saved. If then, during the possession, and
before trial, by the act of God or without fault of the plaintiff,
the property is lost or destroyed, the obligor is not to be held
responsible for the value of its peEiices up to the time of its
death or destruction, or during its detention, or to the time it
ceased to be serviceable.’ The plaintiff in such a case would,
if no eyidence wus given as to the value of the services, recov-
er nominal damages. Where there has been a long delay in
bringing the suit on the bond, or after suit brought it has been
continued for a number of years, the jury is sometimes author-
ized to allow interest on the value from the time of the breach.’
676. General Rule of Damages. We think it may be laid
down as a general rule in an action on a replevin bond, that
the obligee may recover the value of the property at the time
5 Wallace v. Clark, 7 Black 298.
® Stockwell v Byrne, 22 Ind. 6.
® Com. Dig. Condition D. 1 Co Title; Moore v. Crochet, 10 Hum.
(Tenn.) 365; Mosely v. Baker, 2 Sneed 367; Green v. Smith, 4 Col. 440;
Boles v. Patton, 6 Heirk 172.
7 See authorities above; Story v. O’Deal, 23 Ind. 326.
1 Story v. O’Deal, 23 Ind. 326.
? Allen v. Fox, 51 N. Y. 562; Brewster \. Selliman, 38 N. Y. 429
Bomby v. Gibbs, 14 J. R. 385; Young v. Willet, 8 Bosm, 486; Suydam v.
Jenks, 3 Sand. S. C. 614, 620, 621; Adams vy. Adams, 15 Pick. 178; Fitch
BONDS, 581
of the service of the writ and the taking of the property by
the officer, or the value of the property at the time of the trial
and if the property has a usable value it should be allowed in
addition to the value of the property. And as the statutes
of most of the States require the jury to assess the value of
the property and the damages for its detention. It would seem
that the value of the property at the time of the trial is in-
tended. This being true, we think that the measure of dam-
ages might, in case where the right of possession and the right
of property are both found by the jury to be in the obligee, be
easily ascertained by taking the amount of the value as
assessed by the jury, including damages and costs, and com-
pute the interest from the rendition of the judgment up to
the time of the trial. And in those States where the law re-
quires that the judgment shall be rendered in the alternative,
this method is perhaps the only one that should be adopted.’
677. Receiver Defined, and Responsibility and Measure of Dam-
ages on His Bond. A receiver may be defined to be an indiffer-
ent person appointed by the court to receive and preserve the
property or fund in litigation pendentelite, where the court
v. Dakin, 20 Wend. 172; Dorsey v. Gasaway, 2 H. & J. 413; Chapp v.
Walters, 2 Texas 130; Butler v. Mechring, 15 Ill. 488; Banks v. Hallon,
1N. & McC. 221; Ferhenck v. Sewall, 4 H. & J. 398; 2 Dixon 130; Mc-
Ganock v. Chamberlain, 20 Ill. 219; Griffin v. Culver, 16 N. Y. 489;
Blanchard v. Eling, 21 Wend. 342.
3 See authorities above. Upon the condition in a replevin bond to
return the property replevined if return thereof shall be awarded in the
absence of evidence showing the value of such property, and the value
of its use since judgment was given in the replevin suit, only nominal
damages can be allowed. Where the bond recites the gross value of the
property replevined, such recital may be evidence of the value of the
articles mentioned collectively. But if a portion of the property has
been returned to the sheriff according to the condition of the bond, such
recital affords no evidence of the value of the remainder which has not
been returned. Sapris v. Little, 2 Col. T. 496.
582 LAW OF DAMAGES.
has good reason to believe that the interest of the parties liti-
gant will be better protected and preserved in the hands of
the stranger. He is generally regarded as an officer of the
court, exercising the functions of his office independent of the
interests of either the plaintiff or defendant, but for the com-
mon good of all parties in interest. His possession is the
possession of the court; he is sometimes called the hand of the
court. Property in his hands is in the custody and under the
control of the court, and any interference with the property
in the hands of the receiver, by any one, will be punished as
a contempt of the court. The court appointing a receiver
generally requires him to enter into bond, with surety, to
faithfully discharge his duty as such receiver, and account to
the court for all property that may come into his hands as
such receiver. If he fails to discharge his duty according to
the orders of the court, and parties interested in the property
are damaged thereby, they may bring suit on his bond and
recover the actual loss sustained. But it should be remem-
bered that he is not responsible on his bond until he has failed
to obey some order of the court touching the effects placed in
his hands. And if the party who has been damaged by the
misconduct of the receiver wishes to sue him on his bond, if
the receiver has not already violated the order of the court in
reference to the property in his hands, he should make appli-
cation to the court for a rule upon the receiver to render his
account. After the settlement with the court is made, and
the receiver is ordered to deliver the property to the persons
entitled thereto, or surrender them to the court, and refuses to
do so, renders himself and his sureties responsible on his bond
for damages. And in case of the death of a receiver there is a
balance due from him to the estate, the amount of which is
r
? Booth v. Clark, 17 How. 322; Waters v. Carol, 9 Yerg. 102; Baker v.
Adm’r of Bocus, 32 Ill. 79; Devendorf v. Dickenson, 21 Home Pr. 475.
: BONDS. 583
not definitely ascertained, the court on the petition of the par-
_ ties interest will grant leave to bring suit on the bond.
678. Damages that may be Recovered Against the Surety. Asa
general rule the sureties of a receiver will be held responsible,
not only for all sums of principal for which the receiver is in
default, but also for interest due thereon and for which the
receiver is responsible. But the liability for interest is thought
to rest inthe discretionary power of the court. A surety on
.the bond of a receiver is considered in a certain sense as an
officer of the court, and where he has been compelled to pay
out money for the receiver, the court will reimburse him out
of any balance remaining in the receiver’s hands.’
679. Ministerial Officers Suits are frequently brought on
the bonds of constables, sheriffs, marshals and other minis-
=terial officers, for neglect to perform their duties in the service
and execution of legal process. The most frequent suits of
this character are those brought by judgment creditors against
such officers for a failure to levy executions and writs of attach-
ment on property and to sell the same according to law, or a
failure to make returns as the law requires. In an action for
* a breach of official duties, the plaintiff may recover on the
bond full compensation for all loss sustained. For the measure
of damagessee Sections ——, —-,—, ——, under Chapter XIX,
entitled “Public Officers.” The rule is that whatever damages
can be recovered off of the officer for a failure to discharge his
duty, can be recovered in an action on his bond, against him
and his sureties.
2 High on Receivers, pp. 84-87; Griffith v. Griffith, 2 Vt. 400; Hamilton
v. Brewster, 2 Md. 407; Callaghan v. Callaghan, 8 In. eq. 572; O’Keeffe
y. Armstrong, Ir. Ch. N 8.115; Anon, 2 Ir. eq. 416; Averall v. Wade,
Flan. & BR. 341; Maxrell v. Egan, 3 Jr. & Lot. 251; State v. Gibson, 21
Ark. 140; Ledgoter v. Charmel, 3 Mal. & G. 175.
584 LAW OF DAMAGES.
680. General Damages. As a general rule the damages
that may be recovered in an action on the bonds of exec- ,
utors, administrators, guardians and all other officers appointed
by the courts, is regulated by statute, but in the absence of
any statutory provision bearing on the subject, the plaintiff
can recover full compensation for all loss sustained, provided
that it does not exceed the penalty.
681. Consequential and Remote Damages. The rule in an ac-
tion on an official or common law bond is, that the party
suffering from the breach can recover for all the proximate
consequences arising from such breach, but remote or specula-
tive damages cannot be recovered?
682. Bonds on Sale of Liquor. The act. of the Legislature
of the State of Indiana, approved February 27, 1873, required
an applicant who had procured a permit from the Board of
Commissioners of the county where he intended to ‘sell, to
enter into bond, with approved security, for a stipulated
amount. The bond provided that the holder of the license
should pay any and all fines, penalties and forfeitures incurred
by reason of the violations of any of the provisions of the
temperance act, entitled, “An act to regulate the sale of intox-
icating liquors; to provide against the evil resulting from any
sale thereof; to furnish remedies for damages suffered by any
person in consequence of such sale; prescribing penalties; to
repeal all laws contrary to the provisions of this act, and de-
1 Foly v. McKeegan, 4 Ia. 1; Swan v. Steele, 5 Ia. 352; Harrison v.
Wright, 13 East 343; Swan v. Steele, 20 Ia. 374. In an action on an in-
demnifying bond, in which one party obligated himself to save another
harmless from a suit brought for the infringement of a patent, the court
held that the plaintiff was entitled to counsel fees, expense incurred by
himself in making defense for depreciation of his stock, ete. Ripley v.
Moseby, 57 Me. 76; see Carpenter v. Stevenson, 6 Burt Ky. 259; see also
Anti, Chap, XIX, entitled Public Officers.
BONDS. 585
claring an emergency ;” approved February 27, 1873, and con-
ditioned further that “the principal and sureties herein named
shall be jointly and severally liable, and shall pay to the per-
son or persons any and all damages which‘shall in any manner
be suffered by or upon any such person or property, or means
of support, by reasons of any sale or sales of intoxicating
liquors to any person, by the licensee.” The party suing on
these bonds must establish the facts of the injury, and that, it
was the natural and proximate consequence of the act of sell-
ing, or bartering, or giving away intoxicating liquor, to the
one effect by its use. The plaintiffcan recover damages to the
full extent of the injury.‘ .
+ Fountain v. Draper, 49 Ind. 441; Shaffer et al v. The State ex rel Cox.
49 Ind. 460; English v. Beard, 51 Ind. 489. The saloon keeper can only
be held for the natural damages caused by his act. Colly v. Early, 54
Ind. 559; Kelly v. The State, 53 Ind. 311; Kroch v. Heilman, 53 Ind.
417, Fairbanks v. Kerr; 70 Pa st. 80. Where the damages resulting
arise from incapacity for business, and loss of estate caused by such
habitual intoxication ; he who contributes to cause the condition, and it
becomes impossible to separate the damages caused by others from those
caused by the defendant, he is liable for all the damages, if the natural
and probable consequence of his illegal act. Boyd v Watt, 27 Ohio st.
259;, Ruggles v Tilly, 26 Ohio st. 48.
CHAPTER XXXVIIL.
INSURANCE.
Marine InsurANCE DEFINED. SEVERAL RULES oF Con-
STRUCTION. DaMaGEs. GENERAL AVERAGE. ABANDONED
VESSEL. PROPERTY INSURED IN A FOREIGN COUNTRY. F irre
INSURANCE. MortTGaGEr’s RIGHT. NEGLIGENCE IN THE
ASSURED. Damaces. Lire Insurance. Damacess. AccrI-
DENTS.
683. Marine Insurance. Marine insurance has been defined
to be “A contract whereby one party, fora stipulated premium,
undertakes to indemnify the other against certain perils of the
sea.”? In order for the reader to get a clear comprehension of
the subject, we will lay down in as brief and concise manner
as possible, a few well established rules :
1. The commencement and termination of the risk will
depend upon the contract between the parties. If it is stipu-
lated in the policy that the risk is at and from, it includes all
13 Kent’s Com., 251.
1 Field on law of dam., 448,
INSURANCE. 587
the time the ship is in port after the policy is subscribed and
delivered. It may be for the whole voyage, or a part, or for a
specified time. If the insurance is from a designated place,
the risk does not commence until the vessel breaks ground.’
2.
17 L. T. (N. 8.) 289; Terre Haute Co. v. Vanatta, 21 Ill. 188; C. & H. R-
Co. v. Pondrom, 51 Ill. 333; Treaner v- Donhue. 9 Cush. 228; Marshall
v. Gunter, 6 Rich. 6; (S.C.) L. 419; Schul v. Pac. Ins. Co., 14 Fla. 73.
21 Sherman & Wat. New Trials, 409.
NEW TRIALS. 609
new trial in cases of manifested abuse of authority. The law
allows juries great latitude in assessing damages in cases of
torts, and courts seldom disturb their verdicts in such cases
for any reason. And the court should only exercise the power
vested in him by law to grant a new trial in cases where it is
apparent from the amount of ‘the verdict or otherwise that the’
" jury were influenced by passion, prejudice, corruption or evi-
dent mistake of law or facts or that there was a palpable error
in computation. But where the verdict of the jury is clearly
agd unmistakaply excessive, so that it can be readily perceived
that it is wrong and unjust, it should be set aside and a new
trial granted.‘
713. Instances where New Trial was Refused. Welford v. Berkly.
In this case which was an action for criminal conversation and
seduction of the plaintiff’s wife, the jury gave £500 damages.
The defendant moved for a new trial on account that the dam-
ages were excessive. The court was unanimous in the opin-
ion that a new trial should not be granted for that reason.
They held that there was no doubt of the power of the courts
to exercise a proper discretion in setting aside verdicts for ex-
cessive damages, but that such power should only be exercised
where it was apparent that the jury was greatly outrageous in
giving such damages as greatly exceeded the injury’
714 Clouser v. Clapper. In this case, which was an action
_ brought by the plaintiff against the defendant for criminal
conversation and seduction of his wife, the evidence showed
that the defendant was guilty, and that he had been the plain-
+ Walker v. Erie R. R. Co., 63 Barb. 260; Clerk v. Udall, 2 Salk 649;
Macon v. Winn, 26 Ga. 250; Russ v. steamboat War Eagle, 14 Ia 365;
Pleasant-v. Heard, 15 Ark. 403; Green v. Southern Exp. Co., 41 Ga. 515-
5 1 Burr 609; see also Dubby v. Gunning, 4 Term 651; Chambers v.
Caulfield, 6 East 244.
610 LAW OF DAMAGES.
tiff’s family physician. The jury found for the plaintiff, and
assessed his damages at twenty-five hundred dollars. The de-
fendant moved for a new trial on account of excessive dam-
ages. ‘The motion was overruled, and judgment rendered on
the verdict. Appeal to the Supreme Court, where, on hearing,
the judgment of the court below was affirmed.®
715. The Dainages in Cases of Criminal Conversation is seldom
Disturbed. Courts are very reluctant to set aside verdicts and
grant a new trial in cases of criminal conversation. And, up
toa very recent period, it is said that the power of the court
has never been exercised to set aside a verdict in such cases.’
The reason for this reluctance is owing perhaps to the fact that
the injury done the plaintiff in such cases is many times be-
yond an accurate comprehension. But there seems to be no
good reason for the establishing of this exception to the gen-
eral rule. The courts are not authorized to presume that it
would be impossible to assess the plaintiff’s damages too high.
In a recent case in New York, a verdict was obtained against
the defendant for enticing away the plaintiff’s wife. The
Court refused to set asidethe verdict of ten thousand dollars as
excessive, and held that the verdict in such cases should not
be set aside without some other facts than the amount of dam-
ages to show that the jury were actuated by improper mo-
tives.”
659 Ind. 548. In a suit for seduction verdicts are seldom disturbed on
account of excessive damages. Harris v. Rupel, 14 Ind. 209.
‘Smith v. Masten, 15 Wend. 270. In such cases the courts do not in-
terfere without proof of the most flagrant abuse. Grat. & Won. N. Y-
412; Traives v. Bayer, 24 Barb. 614; Tore v. Summers, 2 Nott & McCord
267.
' Scherpf v. Szadeczky, 1 Abb. N. Y. Pr. R., 366. And in another case
the court refused to set aside a verdict of $3,000, although there was
some proof of negligence on the part of the husband. Smith v. Mas-
ten, 15 Wend. 270; see Tullidge v. Walle, 3 Webs. 18; Bennett v. Acock?
NEW TRIALS. 611
716. Personal Injury. Shaw vs. Boston, etc., R. R. Co. In
this case, which was an action brought by the plaintiff against
the defendant for an injury received from a locomotive
through the carelessness and negligence of the defendant’s
agent. There were three different trials, and the plaintiff re-
covered in the first, fifteen thousand dollars, in the second
eigteen thousand dollars, and in the third twenty-two thousand
two hundred and fifty dollars. The defendant had applied for
and obtained two new trials on account of erroneous instruc-
tion. An application to set aside the last verdict on account
of excessive damages was over-ruled, and the finding of the
jury affirmed. ,
717. Walker vs. Erie R. R. Co. This was an action brought
by the plaintiff to recover damages for an injury sustained by
him caused by the defendant, a carrier of passengers. The
wound was one of a very painful character, and of a perma-
nent nature. It appeared in evidence that the plaintiff, when
he received the injury was engaged in an extensive and lucra-
tive business as a lawyer, which business was impaired by his
incapacity to give it the requisite attention. The jury found
for the plaintiff and assessed his damages at twenty thousand
dollars. A motion was made for a new trial on account of ex-
cessive damages. The motion was denied and judgment
on the finding. The court said that under the circumstances
it had no data from which it could say that the verdict of
twenty thousand dollars was excessive.’
2 Term Rep. 166; Sargent v. Dunston, 5 Cowen 106; Clouse v. Clapper,
59 Ind. 548; Tullidge v. Wade, 3 Wilson 18; Brown v. Tanner, 1 Car &
P, 651; Billingsby v. Grover, 5 Ind. 553.
? 8 Gray (Mass.) 288. The Supreme court of Wisconsin refused to set
a verdict of $5,500 for personal injury aside and “grant a new trial, for
the reason that the damages were excessive. Karasich v. Hasbrook, 28
Wis. 569. :
5 6 Barb. 260; see also Clerk v. Udall, 2 Salk. 649; Macon v. Winn, 26
Ga. 250; Russ v. steamb. War Eagle, 14 Ia. 365.
612 LAW OF DAMAGES.
718. So where in an action against a railway company to
recover damages for an injury caused by the defendant’s negli-
gence, it was established on the trial that the plaintiff had
been confined to his bed for a month or six weeks by reason of
the injury received, and further that it had so impaired his
eye sight that in the opinion of physicians who had examined
him he would never recover. After hearing the evidence the
jury gave a verdict for three thousand dollars. On motion for
a new trial for the reason that the damages were excessive,
the court held they were not excessive.*
719. And in an action against a railroad company for in-
jury resulting from its negligence, by which the plaintiff was .
confined to his bed for six weeks, suffered intense pain, and
was unable to attend to business for several months, paid
twelve hundred dollars’ doctor’s bill, and other injuries, and
was left permanently lame, the jury assessed his damages at’
twelve thousand dollars. Motion was made for a new trial on
account of excessive damages. Motion overruled. Appeal to
the Supreme Court. Held that damages were not excessive.°
720. Ryckman vs. Parkins. In this case the plaintiff sued
the defendant for slander and obtained a judgment for seven
thousand dollars. The defendant moved fora new trial on ac-
count of excessiveness of the damages. The court said in the
discussion of the case: “The slander in this case was ofa wan-
* New Jersey R. R. Co. v. West, 32 N. J. L. 91. The Supreme Court
will not interfere with a verdict on the ground of excessive damages un-
less the damages are outragous at first blush. Yates v. Muller, 23 Ind.
562
5 Rockwell v. Third Avenue R. Co., 64 Barb. 438. I wish to know in
a case where a man disregards every principle which actuates a gentle-
man, what is to restrain him but large damages? Merest v. Harny, 5
Taunt. 442; Tullidge v. Wade, 3 Wilson 18; Caldwell v. New Steam-
boat Co., 47 N. Y. 282; Chi. & Alton R. R. Co. v. Wilson, 63 TI. 167.
Chicago R. R. Co. v. Garra. ‘
NEW’ TRIALS. 613
. ton and wicked character, imputing to the plaintiff a crime of
the most atrocious nature, and when the great wealth of the
defendant is taken into consideration there is nothing in the
case to induce suspicion of prejudice, partiality or corruption
in finding a verdict against the defendant to the amount of
seven thousand dollars. A new trial was denied.®
721. In an action for slander the court will not disturb
the verdict of the jury unless it appears that they, in.estima-
ting the damages, were actuated by prejudice, passion, partial-
ity or corruption and for that reason laid the damages in ex-
cess of the real injury or loss sustained.’
722. Exception to the General Rule in Cases of Tort. But it
may be laid down as general rule that in all actions of tort
where the jury finds outrageous damages clearly evincing par-
tiality, prejudice and passion, the court will interpose for the
relief of the defendant andorder a new trial.’
69 Wend. 470; see Clark v. Binny, 2 Pick. 113; Rundle v. Butler, 10
Wend. 119; Bodwell v. Osgood, 3 Pick. 379; 7 Pick. 82; Shute v. Barrett,
7 Pick. 82; Coffin v. Coffin, 4 Mass. Rep. 1; Davis v. Davis, 2 Nott & Me-
Cord 81; Neal v. Lewis, 2 Bag. 204; Redshaw v. Brooks, 2 Wils. 405.
8 Guard v. Risk, 11 Ind. 156; Clark v. McCarty, 5 Black 574; Hogland
v. Moore, 2 Blackford 167, 465. New trial should not be granted in an
action in tort on the ground-that the damages are excessive. unless they
appear at first blush to be outragous.and excessive. Picquet v. McKay,
2 Black 465,
1 Chambers v. Clanfield, 6 East 244; Goldsmith v. Lord Sefton, 3 Anst.
808; Jones v. Sparrow, 5 Term Rep. 257; Chambers v. Robinson, 1-Str.
691; Harry vy. Watson, 4 Term Rep. 659; McConnal v. Humpton, 12
Johns’ Rep. 234; see Graham & Waterman on New Trials, Vol. 1, pp,
442 to 447; Collins y. Albany & Sch. R. Co., 12 Barb. 492; Ill. Cent. R.
Co. v. Welch, 52 Ill. 188; Moor v. Martin, 1 B. Mon. 97; Carning v. Del-
amy, 38 N. Y. 178; Belnapp v R. R. Co., 49 N. H. 374; Doyle v. Dixon,
97 Mass. 208; Mortimer v. Thomas, 25 La. Ann. 165; Peoria Bridge Ass
v. Looms, 20 Ill. 2835; Goodno v. Oshkosh, 38 Wis. 300; Union R. R. Co
v. Hand, 7 Kans. 380; Ill. Cent. R. R. Co. v. Weldon, 52 Ill. 290; Franz
v. Hilderbrand, 45 Mo. 121.
614 LAW OF DAMAGES.
723. Instances where New Trials have been Granted in Cases of
Torts. In one case where the plaintiff brought an action to re-
cover damages for an injury received by the negligence of the
defendant’s servants, though without gross fault. The injury
was on the head, but the most serious injury was on the foot,
so that it became necessary to remove the outside of it, and
one toe. The jury found a verdict for the plaintiff, and as-
sessed his damages at eleven thousand dollars. The court or-
dered a new trial unless the plaintiff would consent to have
the verdict reduced to five thousand dollars.’
724. Inan action brought against a railroad company
for personal injuries, the chief of which was deformity and loss
of power of the right hand, the Supreme Court of the State of
Kansas held that a verdict of five thousand dollars was excess-
ive damages, and reversed the judgment and ordered a new
trial.’ .
725. McConnell v. Hampton. In this case, which was an
action for false imprisonment, the defendant was commander
of the United States army at Burlington, when the plaintiff,
a private citizen was arrested and tried by a court martial.
The plaintiff came to the defendant to make some communi-
cation relative to the enemy, and the defendant said the com-
munication was false, and ordered the plaintiff to be taken to
the guard house. The plaintiff was confined from Tuesday
1 Collins v. Albany & Sch. R. Co.. 12 Barb. 492; Murry v. Hudson R.
R. Co., 47 Barb. 196. In case where a brakeman was employed at $40
per month, and lost an arm through the negligence of the railroad com-
pany, and recovered against it $10,000, the Supreme Court of Illinois
held that the damages were excessive, and granted a new trial. III.
Cent. R. R. Co. v. Welch, 52 Ill. 183; Moore v. Masten, 1 B. Mon. 97.
’ Union Cent. R. Co. v. Hand, 7 Kans. 380. It is the province of the
court to see that justice is done, and when the assessment is manifestly
unjust, whether too small or excessive, a new trial should be granted.
Mobile & Mont. R. Co. v. Ascheraft, 48 Ala. 15.
NEW TRIALS. 615
until Sunday, and lay on the floor of the guard house without
any bed, but was allowed to procure his own provisions and
ratioris of a soldier, and was permitted to speak to others in
the presence of the officer. The jury found a verdict for nine
thousand dollars damages. A motion was made to set aside
the verdict, and for a new trial. The court held that the dam-
ages were such as to strike every one at first blush that the
verdict was unreasonable and indeed outrageous, and awarded
\
a new trial.*
726. Reduction of the Verdict. It is a common practice
among courts when they consider the damages excessive
to order a new trial, provided the plaintiff does not re-
duce the judgment to what the court considers a reason-
able sum under all circumstances. If the reduction is made
the motion will be over-ruled; or if the reduction is not made,
then the verdict will be set aside and a new trial granted.
Thus in Ohio, where a judgment on a bill was entered for too
large a sum of damages on error, the plaintiff was allowcd to
remit the excess, and keep his judgment, on payment of
costs.*
727. The General Rule. It may be laid down as u general
rule that the plaintiff may, by permission of the court, when
® 3 Monroe 145; 2 Southard 847; Chicago & C. R. Co. v. Fellmore, 57
Ill. 265; Chicago & N. W. R. Co. v. Jackson, 55 Ill. 492. This was an
action brought by a brakeman for an injury sustained by him by reason
of negligence of the railroad company, and it appeared that the plaintiff
in attempting to descend a ladder while the train was in motion, in
obedience to a signal from an engineer, lost his hold by reason of a de-
fect in the ladder, and fell to the ground and the wheels of the cars
passed over his legs, injuring them so that amputation became neces-
sary, and he recovered judgment for $18,000. The Supreme court of
Illinois set the verdict aside for the reason that the damages were ex-
cessive. 55 Ill. 492; see Murry v. Hud. R. R. Co,, 47 Barb. 196.
* Doty v. Rigour, 9 Ohio st, 519.
616 LAW OF DAMAGES.
the damages assessed are excessive, remit the excess of the
amount claimed, and take judgment for the balance, and in
this way defeat the defendant’s motion for a new trial?
728. Where a jury by mistake, or otherwise, finds more
than the plaintiff claims, that is no reason for setting aside a
verdict and granting a new trial if the plaintiff will remit
the excess and let judgment be rendered for the sum to which
he is entitled. It is sometimes quite difficult to tell exactly
what amount ought to be remitted in order to reduce the dam-
ages to the actual loss sustained. But thisis necessarily left to
a great extent to the judgment of the court.®
729. Wherethe Motion is based on Inadequacy of Damages. Be-
fore a court-will set aside a verdict and grant a new trial, it
must appear clear that the jury have abused their power.
Thus when the plaintiff brought an action to recover damages
for injuries suffered when traveling on the defendent’s ruail-
way, through the neglect of their servants. A verdict having
passed for the plaintiff with £700 damages, an application was
made to this court for a new trial, on behalf of the. plaintiff, on
the ground of the insufficiency of the damages, as well as of
misdirection, as having led to an insufficient assessment of
° Pierce v. Payne, 14 Cal. 419; Teagarden v. Hatfield, 11 Ind. 522;
Blunt v. Little, 3 Mason 102; Armitage v. Haly, 4 Q. B. 917; 12 L. J. Q.
B. 323; Deblin v. Murphy, 3 Sandf. (N. Y.) 19; Anderson v. Tarpley,
14 Miss. 507; Connelly v. McNeil, 2 Jones (N. C.) L. 51; Doby v. Re-
gour, 9 Ohio st. 519; Fostrr v. Van Norman, 1 Tex. 636. When the ver-
dict is a greater sum than all claims made, and in all cases where the
judgment is in excess of the amount claimed, a new trial should be
granted, unless there is a remittance. Griffin v. Weatherspoon, 8 Ga.
591; Steadman v. Simmons, 39 Ga. 591; Atwood yr. Gilapsie, 4 Mo. 423;
Cross v. Wilkins, 43 N. H. 332; Pinckny v. Pulrife, 9 IN. 79; 11 Ind. 31;
Rowan v. People, 18 Ill. 159.
* Steadman v. Simmons, 3 Ga. 591. But crediting the judgment with
the excess will not have the same effect as a remittur. Graham & Wat-
eman on New Trials, 1162.
NEW TRIALS. 617
damages, and we are of the opinion that the rule for a new tri-
al must be made absolute—not, indeed, on the ground of mis-
direction, for we are unable to find any misdirection, the
learned judge having, in effect, left the question of damages to
the jury with a due caution as to limited compensation, though
we think it might have been more explicit as to the elements
.of damages. "No doubt as to the general rule as to where an
injury is caused to one person by the wrongful or negligent
acts of another, the compensation should be commensurated
to the injury sustained. But there are personal injuries for
which no pecuniary damages would afford adequate compensa-
tion, while on the other hand, an attempt to award ull com-
pensation in damages, might be attended with ruinous conse-
quences to the defendants, who cannot always, by the utmost
care, protect themselves against the carelessness of persons in
theiremploy. Asa general thing we agree with the rule laid
down by Mr. Justice Brett, in Rowley v. London, X8:* * *
That a jury in these cases must not attempt to give damages
to the full amount of perfect compensation for the pecuniary
injury, but must take a reasonable view of the case, and give
what they consider under all the circumstances a fair compen-
sation. And this is, in effect, what was said by Mr. Justice
Field to the jury in the present case. But we think that a
jury cannot be said to take a reasonable view of the case un-
less they consider and take into account all the heads of dam-
‘ages in respect to which the plaintiff, complaining of a
personal injury, is entitled to compensation. There are bodily
injuries sustained, the pain undergone, the effect on the health
of the sufferer, according to its degree and its probable duration
as likely to be tempororary or permanent, the expense inci-
dental to effect a cure or to lessen the amount of injury, the
loss sustained through inability to attend to business or pro-
fession, which, again may be of a temporary character or may
421 W.R 869; L. R. 8 Ex. 231.
618 LAW OF DAMAGES.
be such as to incapacitate the party for the remainder of his
life. If a jury have taken all these elements of damages into
consideration, and have awarded what they deemed to be a fair
and reasonable compensation under all these circumstances of
the case, a court ought not, unless under very exceptional cir-
cumstances, disturb their verdict. But look to the figures in
the present case, it seems to us that the jury must have.
omitted to take into account some of the heads of damages
which are properly included in the plaintiff’s claim. The
plaintiff was a man of middleage, and of robust health. His
health had been irreparably injured to sucha degree as to render
life a burden, and a source of the utmost misery. He had un-
dergone a great deal of pain and suffering, and the probability
isthat he never willrecover. His condition is at once helpless
and hopeless. The expenses incurred by reason of the accident
have already amounted to £1,000. Medical attendance still is
and is likely to be fora long time necessary. He was making
an income of £5,000 a year, the amount of which had been
positively lost for sixteen months, i. e., between the accident
and the trial, through his total incapacity to attend to his pro-
fessional business. The positive pecuniary loss thus sustained
all but swallows up the great portion of the damages awarded
by the jury. It leaves little or nothing for health permanent-
ly destroyed, and income permanently lost. We are therefore
led to the conclusion not only that the damages are inadequate
but that the jury must have omitted to take into considera-
tion some of the elements of damages which ought to have
been taken into account. The court granted a new trial.
730. In New York, where the jury gave the plaintiff $10
damages in an action for injury sustained by the negligence of
° Phillips v. London & Southwestern R. Co., in Queen’s Bench, 9 Am,
Cent, Law Jour., p. 125.
NEW TRIALS. 619
the defendant, whereby the plaintiff was severely bruised upon
his face, and one of his teeth knocked out, the court held that
the amount was grossly inadequate, and that the plaintiff was
entitled to a new trial on the payment of costs, unless the de-
fendant should consent to a material increase of the amount of
damages found by the jury.®
731. The General Rule. Where it appears that the ver-
dict is less than the amount due; or in an action to recover
the value of personal property wrongfully taken or unlawfully
detained, the verdict is less than the value of the property
taken or retained; or for a personal injury, the verdict is less
than the actual expense paid for the attendance of a surgeon
or physician; or when the verdict is clearly inadequate and
not commensurated by the injury sustained, the court should
grant a new trial."
782. Asa general rule courts will refuse to-set aside ver-
dicts for inadequacy of damages, whére there is no evidence
that the jury were actuated by bad motive; or where another’
trial would result in so small a change as to be of no benefit to
the applicant; or where substantial justice has been done.®
‘6 Richards v. Sanford, 2 E. D. 8. 349; Brown v. Seymour, 1 Wils. 5;
Aurlen v. Hilliers, Hord. 208; Robinson v. Hudson Riv. Co., 7 Bosm.
(N. Y.) 1; Caste v. Nichols, 42 Mo. 169; Hall v. Bark Onily Banning,
38 Cal. 522; McDonald v. Waters, 40 N. Y. 551. Mariana v. Dougherty,
46 Cal. 26. ‘
7 Collins v. The Albany & Sch. R. Co., 12 Barb 492; Protens v. Hazel,
1 Harper 312. The defendant may be agreeing that the damages may be
increased to an amount that is just and reasonable, defeat the plaintiff’s
motion for anew trial. Robinson v. Hudson R. R. Co.,7 Bosm. (N Y.)
1. But where the jury fails to assess the amount due, the court cannot
ascertain the amount and render judgment thereon. Coats v. Nickells,
42 Mo. 169. ’
6 Howard v. Barnard, 11 C. B. 653; Gibbs v. Tunnell, 1 C. B. 649; Phil-
lips v. Phillips, 3 N. J. L. 208. An omission to assess nominal damages
when there is a mere technical right to recover, is no ground for a new
trial. Hudspeth v. Allen, 26 Ind. 165; Frank v. Kessler, 30 Ind. 8.
620 LAW OF DAMAGES.
733. In writing this chapter it has not been our inten-
tion to discuss at any great leugth the law relating to new
trials, but only to notice it so far as it involves the question
of damages. But from what we have said, the student will
readily see that it is with great reluctance that courts inter-
fere with the verdicts of juries in cases of personal torts. And
the reason for this is that there is no scale by which the dam-
ages in such cases can be graduated, other than the intelli-’
gence of the jury, governed by a sense of justice and natural
right. The law clothes the jury with authority to hear the
evidence, and to award the injured party such damages as will
equal the injury sustained, and the court must presume that
they have performed their duty until it clearly appears other-
wise. And it is only when the result appears in a form calcu-
lated to shock the understanding, and shows no dubious con-
nection of their prejudices and passions, that the courts have
found themselves compelled to grant new trials. But in all
actions where the damages are liquidated, or are shown by the
argument of the parties or from any other cause, a reasonable
certain measure of damages is awarded, the jury is allowed no
latitude, “and the court will look to the circumstances, and
grant or refuse a new trial, or correct the verdict, according to
the justice of the case.’””
'1 Graham & Waterman on New Trials, pp. 452, 453.
INDEX.
THE NUMERALS REFER TO SECTIONS.
A.
ASSAULT AND BATTERY, DEFINED, 63.
the defenses that may, be set up in an action for injury by assault and
battery are numerous, 64.
the elements of damages, 65,
the rules of the assessment of damages, 66,
aggravate circumstances may be shown, 67.
exemplary damages some times allowed, 67, 31.
mitigating circumstances may be shown, 68, ,
before provocation can be shown in mitigation of damages it must ap-
pear that they were so recent as to influence the defendant’s con-
duct, etc., 69-73.
the plaintiff’s character is not in issue, 70.
good name of defendant cannot be shown in mitigation, 71.
the res gesta may be shown, 72-75,
the passions of the mind recognized, 76.
the degree of force that one may use to defend himself, 76.
a person may act on appearances, 77.
in self-defense unnecessary force should not be used, 78.
when a blow will be justified, 79.
exemplary damages’ right to recover questioned, but allowed in certain
’
/
cases, 81, 82.
the assailed party need not flee, 83.
damages that plaintiff may recover under the general allegation of his
complaint, 84.
a full detense, 83.
injury done in self-defense unintentional injury.
done in the prosecution of a lawful act, 85.
in chastising a seaman, 87.
school teacher in punishing his pupil, 88.
a parent in correcting his child, 89.
corporation liable for assault and battery, 9I.
ATTORNEYS, when responsible in damages, 333.
the measure of damages in case of suit against, 334.
ATTACHMENT bonds, (see official bonds), 655, 656, 658, 659.
ARBITRATION bonds. see sections 661, 662, (See official bonds).
APPORTION damages, 7.
622 LAW OF DAMAGES,
5B:
BREACH OF PROMISE TO MARRY, pleading generous time when
should be stated, 380.
the complaint should show that the defendant had neglected or refused
to marry the plaintiff, 380.
what the plaintiff must prove,in order to make out her case, 381
the elements of damage, 382.
the damage, 382.
exemplary damages sometimes allowed, 333.
when exemplary damages are allowed, 384, 385.
full defense, 386,
plaintiff's misconduct when.a defense, 386.
infancy when a good defense.
marriage prohibited by laws of the State, 386.
bad health of the defendant when a defense, 386.
the damage at the discretion of a jury, 387.
seduction, when allowed to be shown to enhance the damages, 388.
in the States having laws allow a female to bring an action for her own
seduction, when seduction may be shown to enhance the damages, 388.
mitigating circumstance, 389.
matters that cannot be considered as a defense, 390.
BAILMENT defined, section 587.
the division of the subject, 587.
deposition, 588.
mandatum, 589.
commodatum, 590.
pignus, 592.
damages, 592, 593.
division of the class of locatis, 596.
warehouse and whartages, 597.
innkeeper, 598.
common Carriers, 599.
care required and responsibility fixed, 599.
exception to the general rule as to live stock, 600.
responsibility of carriers; how far regulated by contract, 602-604
commencement and termination ot the common carrier’s liability, 601,
602, 603.
damages when common carriers refused to carry goods, 605.
general rules of damages, 606,
when enhanced damages, mav be recovered, 607.
carrier responsible for the necessary consequence of his own act, 607.
responsibility of the carrier who attempts to carry goods beyond his
line, 608.
responsibility of each line, 6o9.
the carrier has his line for freight, 610.
full defense, 611.
INDEX. 623
BAILMENT— Continued.
when he will be excused from damages in case of loss, 611.
mitigating circumstances, 612.
what the carrier is bound to take notice of, 613.
carrier of passengers, 614.
his responsibility, etc., 614.
baggage carrier responsible for, 615.
full defense, 616,
breach of contract to furnish freight, 617.
damages, 617.
duty of the plaiutiff to prevent loss, 617, 618.
C..
CRIMINAL CONVERSATION, at common law an action lies in favor
of a husband for criminal conversation and seduction ot his wife, 92.
in an action for damages plaintiff must prove actual marriage, 93, 94.
how the adulterous intercourse may be proved, 95.
time and place need not be proved with great particularity, 96.
anterior act of adultery may be shown when, 97.
state of domestic happiness between plaintiff and his wife may be
shown, 98, 99, Too.
the wife’s character presumed to be good, 102,
wife’s character in issue, I1os-104.
after particular instance of misconduct on part of the wife have been
shown, the plaintiff cannot rebut by good reputation, 103.
the opinion of a witness as to the affection existing between plaintiff
and his wife not admissible, 105.
mitigating circumstances, 106,
the defendant may show in mitigation of damages that the plaintiff
after he knew his wife had been guilty of adultery with the defendant
that he continued to live with her, 106.
that the plaintiff and wife lived unhappily together and that the plain-
tiff abused her, 107.
COLLISION, damages for misconduct of defendant, 199.
damages where both parties are at fault, 200.
the moiety rule when applied, 2or.
damages in case of injury not resulting in total loss, 203.
damages by the negligence of two vessels and who are responsible, 203.
the different cause of the collision, 204.
elements of damages, 205
plaintiff who has been injured by acollision may sue atcommon law, 206,
contributory negligence will not defeat plaintifi’s claim under certain
circumstances, 207.
cargo, when may recover for loss of, 209,
the act of God a good defense, 210,
COPY RIGHT, action may be maintained for infringement of the right, 317.
the measure of damages, 318, 319. [See Patent Law.]
624 LAW OF DAMAGES.
COVENANT OF WARRANTY, the American common law relating
to real property had its origin in the feudal system, 361.
the rights of the vassal, 392.
the fudal grant was hereditary, 392.
the law of real property much confused in this country, 393.
the overthrow of the feudal system, 394.
the covenants in a deed, 394.
the common law of the United States, 395.
the grantor cannot recover substantial damages until he has sustained
an injury, 396.
the covenint is not considered broken until there is a hostile claim of
title, 396.
the duty of the grantor to wait until some one asserts a hostile claim
before he brings his action, 397.
general question considered, 398.
damage, purchase money, legal interest and expense, 398.
objection ‘to the rule of damages, 398.
objection noticed and discussed, 399.
states in which this general rule has been Bae 400,
the objections discussed, 400.
reason for both rules, 4o1.
the new rule, 401.
damages where a part of a tract is taken, 402.
the right of the plaintiff to recover interest, 403.
interest only to be allowed from the time of the loss of the mesne
profits, 403.
full compensation for all loss the rule of damages, 404.
damages where the covenant of seizin is broken and the grantee evicted
purchase money with interest, 404.
after acquired title inures to the purchaser, 406.
does the covenant of seizin run with the land, 407.
American and English rules, 408,
covenant for a good right to convey, 409.
covenants against incumbrance, 4q1o.
damuges for breach of covenant against incumbrance where the grantee
has not been evicted or injured or paid off incumbrance a nominal
sum, 411.
notice of the different rules, 413.
damages where the incumbrance cannot be removed, 414.
covenants sometimes change, 415.
covenants for quiet enjoyment and warranty, 416.
damages in case of breach of such covenants, 416.
exception to the rule, 417, 418.
costs and counsel fees sometimes allowed, 419.
mitigating circumstances, 420.
COVENANT REAL, executory contract for the sale of land, 421.
INDEX. 625
COVENANT REAL—Continued.
damages in case of breach, 421.
general rule for damages where the vendor acts‘in good faith, 422.
general rule where the vendor acts in bad faith, 423.
rule in New York, 414, 425.
when defendant acts in good faith.
purchase money with interest, 426, 428.
Engitish rule, 427.
rule in case of Hadly v. Baxendale applies, ,429.
damages where the defendant acts in bad faith, 430.
good and bad faith.
Indiana rule purchase money with interest, 432.
in Maine the value of the land at the time of the breach the measure of
damages, 433.
decisions that ignore good or bad faith, 434.
damages in case of failure of the vendee, 435.
damages where deed is tendered to the vendee, 437.
the proximate consequence can only be considered, 438.
price agreed to be paid with interest considered the measure of dam-
ages, 4345 435-
the difference between the price fixed. in the contract and the saleahie
value of the land the measure of damages, 437.
should the malice be considered, 439.
rescission of contract, 440.
damages in case of a breach of contract to lease land, 441.
CONSEQUENTIAL DAMAGES, 4, 6.
See Warranty, Fraud and. Negligence.
iD.
DUTY OF THE INJURED PARTY- TO PREVENT LOSS, the
plaintiff must be active to prevent loss, 372, 373.
rule illustrated, 374.
if the injured party fails to use reasonable means to prevent loss he can
only recover such damages as he could not have prevented, 375.
the rule applied in case of contract to perform work, 376, 377.
the general rule imposed by law, 378.
damages where the injury is enhanced by the negligence of the plain-
tiff, 379.
DIRECT damages, 4.
damages defined, 1.
recompense or satisfaction for some injury sustained, 1
“Bi.
EMINENT DOMAIN.
any sovereign may take private property for public use, 34.
the reason for exercising the right of eminent domain, 304.
how property may be taken by the State, 305.
626 LAW OF DAMAGES.
EMINENT DOMAIN-—-Continued.
this right should be exercised with great care, 305.
the title that the State may acquire by eminent domain, 306.
the damages that the owner of the land may recover, 307.
benefits that the owner of the land shares in common with others,
should not be considered, 307.
the damages, how ascertained, 307.
the measure of damages is compensation for every injury sustained, 308,
.
EXEMPLARY DAMAGES, the right to recover, a source of contro-
versy, 33.
it never was a rule of the common law, 34.
this is evident the meaning of the word damages, 36.
the law aims to restore loss, 37.
the jury not authorized to assess, 38.
the argument in favor of the rule, 39.
the issue at common law forbids the recovery of exemplary-dam., 40.
controversy between Greenleaf and Sedgwick, 41.
effort to reconcile their difierences, 42.
Supreme Court of Iowa 43.
damages for mental suffering, hard to estimate, 44.
the rule for the assessment of exemplary damages adopted in this
country, 45.
decision of the Supreme Court of the United States, favoring such
damages, 46.
the dispute on the question of assessing such damages where the in-
jury was caused by an act that is punishable as a crime, 47, 48.
principal liable in exemplary damages for acts of his agent, 49.
so the master for his servant, 50.
principal not liable for malicious trespass of his agent, sl,
common carriers liable for exemplary damages, 53.
corporation liable in exemplary damages, 54.
opinion of the Court of Appeals af New York, 54.
the peculiar condition of the defendant not to be considered in aseess-
ing exemplary damages, 55
when and for what injuries exemplary damages allowed, 56.
allow in cases based on fraud, malice, gross negligence or oppression.
principal defined, 57.
gross negligence defined, 58.
allowed in breach of contract to marry, 59.
not allowed in case of an injury by a domestic animal, unless the ow-
ner knew the animal to be vicious and disposed to injure mankind, 60,
infants, non compos mentis, not liable for, 61.
the nature of the offense should be considered, 62,
allow in case of assault and battery, 67, 81. 82.
INDEX. 627
ENTICING AWAY A SERVANT,
where one entices away a servant of another, damages may be re-
covered, 354.
but only the proximate consequences can be recovered, 354.
remote damages caunot be allowed, 354.
damages foi enticing away a servant who is employed by the job, 355.
the employer must use reasonable means to supply his place, 355.
the relations of the parties to be investigated, etc., 52.
B.
FALSE IMPRISONMENT, DerFinep, 113.
the right of private citizens and peace officers to make arrests, 114, 116.
after they make an arrest must take the prisoners foetal es before an
officer and prefer charges, 117.
arrest under a warrant, 118.
arrest under a void warrant, II.
officer liable for arrest under a writ where the court had no jurisdic-
tion; 120.
ministerial where he pleads justification, must auetail it by his proof, 121.
elements of damages, 122.
matters that may be shown in aggravation, 123.
mitigating circumstances that may be shown, 124.
full defense 125, 126.
FRAUD AND DECEPTION,
fraud defined, 127.
bad intention, when considered, 128.
fraud can only be committed in the misrepresentation of a material
fact, 129.
misrepresentation as to what the law is never considered fraud, 130.
vague commendation not fraud, 131.
the representation must be such as the party had a right to rely
upon, 132.
the law never relieves the negligent, 133.
representation as to price paid as to the value or what he has been of-
fered for it are not fraud, 134.
the law raises no presumption of fraud without proof, 135.
the party who has been defrauded has one or two remedies, he may
rescind or sue for damages, 137, 140.
the plaintiff must be active in enforcing his remedy, 138.
if he rescinds, he must do so in toto, 139.
the damages, 141.
the rules for the assessmént of damages where there are numerous
representations, 141. |
representation of soundness.of property in case of exchange, 143.
the general rule of damages, 143, 144.
damages in case of fraud in the sale of real estate, 146.
rule of damages where there are false representation as to the quan-
tity of land, 146, 147.
628 LAW OF DAMAGES.
Ge
GUARANTY De Finep, 518.
‘ confusion of surety and guarantor, 518.
distinction between surety and guarantor. 518, 520,
damages in case of breach, 521.
tet.
HIGH WAYS, the rights of a traveler when they are obstructed, 29.
i
INSURANCE, MarINE, 683. .
commencement and termination of the risk depends on contract, 683.
rules established for constructing contracts of insurance, 683.
how to estimate the damages, 685.
the measure of damages, 686.
the value ot the ship at the commencement of the risk, allow reason-
able amount for wear and tear in estimating damages, 686,
the reason for the rule, 687.
damage in case of total loss of cargo, 688.
general average, when allowed, 686,
the insurer allowed to repair in reasonable time, 6go.
abandoned vessel, 690.
how to assess the damages on goods ina foreign county, 691.
Fire INSURANCE, defined, 694.
the measure of damages in case of loss, 693,
mortgagee entitled to damages, 694.
negligence on the part of the insured, when it will prevent a recov-
ery, 695.
damages when there is more than one insurance on same property, 695.
defense that may be set up to the recovery on policy, 607, 608.
right of the insurer to rebuild under the contract, 699.
damages where the party commences to rebuild and fails, 699.
LiFe INSURANCE, contract of, 700,
measure of damages, in case of death, 7or.
creditor has an insurable interest in his debtor, 702,
the damages that may be recovered, 703.
INTRODUCTION,
the discussion of the question of damages, 1,
the law upholds man in his natural rights, 2.
the common law, its expression.
the assessment of damages uniform, etc., 3.
direct and remcte consequences, 4.
law looks to rules, 5.
the proximate cause, 6.
the wrong-doer will not be permitted to apportion his damages, 7.
the law requires a man to be active to prevent loss, 8.
INDEX. 629
INTRODUCTION— Continued.
exemplary damages, 9.
liquidated damages, ro.
contributory negligence, Ir.
the complaint.
the damages that necessarily arise can be shown under the general de-
nial, 14.
province of the jury at common law, I5.
damages for the proximate consequence for breach of contract can be
allowed, 16.
Hadly v. Baxendale, 17.
recovery measured by the interest of the party plaintiff, 18.
discussion of the question of exemplary damages, 18, 19, 20.
LL,
LUNATICS are responsible for their torts, 30.
LIBEL AND SLANDER,
libel defined and slander defined, 268.
malice essential in an apna of slander, 269.
elements of damages.
‘mental suffering, circumstances of indignity, public disgrace, etc.,
should be considered, 271.
special damages. when allowed, 272.
what may be considered as such, 272.
-what constitutes a full defense, 275.
words spoken in the discharge of official duty, etc., not actionable, 275.
mitigating circumstances, when they may be shown, etc., 276,
LIGHT, the common law of England in reference to light not the common
law of this country, 351.
the common law of America, 352.
some of the States hold that an easement may be acquired over the
land of an individual for the use of light, 353.
LANDLORD AND TENANT,
hiring of real property, 442.
liability of the landlord, 443.
implied covenant on the part of the landlord, 443.
landlord need not renew, 443.
damages by breach of contract by landlord, 444.
lessee’s measure of damages where he has been prevented from taking
possession, 444.
damages 1n case of failure to make repairs, 445.
damages for failing to keep gate in repair, 445.
damages for failure to repair a house, 446.
who to repair, 448. :
damages where the tenant is evicted by the landlord before his lease
expires, 449, 450.
consequential damages, 451.
*
630 LAW OF DAMAGES.
LANDLORD AND TENANT— Continued. °
actual loss sustained, 452, 453.
gratuitous labor by the landlord on the leasehold premises, how to be
performed, 504.
the rule in case of Hadly v. Baxendale applies, 455.
the right of the landlord to enterupon the premises after the expira-
tion of the defendant’s lease, 456.
general liability of the tenant, 457.
must take possession of the leasehold estate at the time specified and
perform his other obligations, 457.
the tenant’s obligation to repair, 459.
what tenant cannot show in defense, 460.
the improvements the tenant may remove, 461.
when he must remove them, 461.
waste, when tenant responsible for. 462.
damages, actual loss sustained, 463. P
waste defined.
LIQUIDATED DAMAGES,
the right of the parties to fix the amount of damages for a breach by
contract, 640. I
the intention of the parties always carried out when it can be ascer-
tained, 640.
the law ot liquidated damages in confusion, 642.
the difficulty arising in the way of having a definite rule is the ambig-
uity of the contracts, 643, 644.
construction of the contract, 041, 642, 643; 644. 645.
exception to the general rule for construction, 646.
where a large sum is made payable, on failure to pay, a small one, how
considered, 647, 648, 649.
stipulated amount allowed as a penalty, 650, 651, 652, 653.
law looks te particular rules, etc. It never encourages. 5.
litigation, 21.
IM.
MALICIOUS PROSECUTION, DEFINED, 170.
probable cause, 171.
what the plaintiff must prove, 175.
malice, how proved.176.
what evidence required to prove,
a want of probable cause and malice, 177, 178.
the plaintiff must show in order to make out his case: 1, that the pros-
ecution is atan end; 2, that the prosecution was instituted malic-
iously ; 3, the want of probable cause; 4, that he has been dam-
aged, 180,
full defense, 181.
elements of damages, 182.
the damages, 182,
3}
INDEX. 6381
MALICIOUS PROSECU1T'ION—Continued,
mitigating circumstances, 184.
jury, ther power, 185.
corporation liable for malicious prosecution, 186°
MARRIAGE CONTRACT, (See Breach of Promise.)
MITIGATING CIRCUMSTANCES,
the aim of the law to measure the damage by the injury, 356.
in case injury to goods by co:nmon carrier, he may show in mitigation
that the plaintiff received goods in damaged condition, 357.
the malicious intention should be considered, 358, 359.
mitigating circumstances in libel and slander, 360, 361.
mitigating circumstances may be shown in case of malicious prosecu-
tion, 362.
mitigating circumstances in case of false imprisonment, 363.
mitigating circumstances in case of an action against an agent, 364,
mitigating circumstances in trover, 365,
mitigating circumstances may be shown in suit on contract, 366,
case of malice, 367. ,
mitigating circumstances in case of criminal conversation, 368.
mitigating circumstances in seduction, 369.
mitigating circumstances in case of a breach of promise to marry, 370.
good faith, 371.
\
N.
NOMINAL DAMAGES, in case of action for labor, 340.
nominal damages in case of breach of contract, 341.
nominal damages may be recovered for failure to pay check, 342.
in case of breach of covenant, 343.
objections to the rule, 344.
NUISANCE, DEFINED, 187.
the different kinds of nuisance, 188,
plaintiff’s remedies, 189. i
right to abate a nuisance. 190, Igt.
who responsible for nuisance, 192.
damages in case of nuisance, 193.
opinion of Supreme Court of Pennsylvania on the question of dam-
ages, 194.
Supreme Court of Indiana, 194.
dangerous animals running at large a nuisance, 195.
dog running at large a nuisance, 196.
the right of adjoining land owners, 198.
NEGLIGENCE, Derinep, 211.
in order for plaintiff to recover, it must be a case of unmixed negli-
gence, 212.
when negligence of defendant is so gross as to imply a disregard of
consequences, or a willingness to inflict the injury, the plaintiff may
recover, 213.
632 LAW OF DAMAGES.
NEGLIGENCE— Continued.
Illinois rule, 214.
the right to use property does not authorize one to do wrong, 216.
instances of gross negligence, 218, 219, 220, 221, 222,
negligence in injuring a child, 223.
negligence of parents, etc., attributed to the child, 223.
the authorities are in conflict as to whether the negligence of the pa-
rent, etc., should be attrributed to the child, 224.
a child is only required to exercise such care as one of his age, 225-6,
when the action is brought by the parent for the injury to the child, his
negligence is attributed to the child, 227.
greater care required of the defendant when children are exposed to
danger, 228.° *
drunkenness, what care required in case of, 229.
blind, insane, and foolish, the care required, 230.
negligence, a question of law and fact, 231.
when negligence will be imputed to one in the act of saving life, 233.
what the defendant will be held responsible for, 234, 235.
the rule to ascertain defendant’s liability, 236. .
‘the’ first efficient and adequate cause as well as any intermediate
cause, etc., considered the proxim ite cause, 236.
the measure of damages, 238, 239, 240.
damages case of personal injury, 241, 242.
elements of damages, 251.
in assessing damages all the facts should he considered, 243.
rule for the assessment of damages in case of injury to real and per-
sonal property, 244, 247, 246.
malpractice,’ 247.
damages in case of malpractice, 247.
INJURY BY NEGLIGENCE, Resur-TING IN DEATH. At common law,
no activi could be maintatned for an injury resulting in death, 250.
Lord Campbell’s act, 251.
the act of the State of New York, 252.
the act of the majority of the States like the N. Y. act, 253.
the damages that the plaintiff may recover compensation, 255.
the plaintiff cannot recover for mental suffering of the deceased, or for
the mortification of his relatives, 255.
the pecuniary damages may be recovereil, 255.
the damages must be of a pecuniary character, 256.
the expectation to be considered, 258.
limitation of damages, 260,
damages how enhanced. 261.
damages that a child may recover for the loss of its parent, 262.
how the damages should be estimated, 263.
elements of damages, 263.
the damages that parents may recover for the death of their child, 264.
INDEX. . 633
NEGLIGENC E— Continued.
in some States the statutes authorize parents to bring the action in
their own name, but the ule for the assessment of damages is the
same, 265,
. contributory negligence, when it will defeat a recovery, 267,
where there is a breach of an agreement or evasion oi a right estab-
lished, the law infers some damages, and if the party shows no loss
nominal damages may be allowed, 336, 339.
in purchase of real estate.
in an action for breach of an agreement to convey land where no
money has been paid and the vendor has acted in good faith, nominal
damages may be recovered, 338.
in all cases where the evidence shows an injury and no proof is shown
of amount of damages, nominal damages may be recovered, 339.
NEW TRIALS,
when a new trial will be granted for excessive damages.
new trials are never granted unless the damages are so excessive as to
warrant the belief that jury must have been improperly influ-
enced, 711.
the reason for the rule, 712.
instances where new trials have beeu refused for such reason, 713-721.
exception to the general rule, 722.
instances where new trials have been granted, 723-725.
new ‘trial in some cases refused when there is a reduction in the ver-
dict. 728,729. =
new trial on account of inadequacy of damages, 729.
instances where new trials have beeu granted on account of inade-
quacy of damages, 730. ,
when it appears that the verdict is less than the amount due, new trial
is gnerally granted, 731, 732.
the intention of the author, 733.
OFFICERS,
courts and their object, 322.
no judicial officer can be held responsible for his deeision, 322.
judicial officer, when responsible for his acts, 328.
court having no jurisdiction of the subject matter, liable for his
. acts, 324,
measure of damages is full compensation, 328.
prisoner, negligent escape, the measure of damages that can be recov
ered against an officer, 329.
law presimes an officer has done his duty, 330.
exemplary damages are sometimes allowed, 331.
mitigating circumstances, 332.
attorneys, when responsible for damages, 333.
damages for being kept out of office, 335.
os
634 ° LAW OF DAMAGES.
OFFICIAL BONDS,
damages, as a general rule the damayes will be limited to the actaal
loss sustained, 655.
the extent of the plaintiff’s recovery, 656.
exception to the rule, 656, 657.
attachment, bond suit on, 658.
damages on bond, 659.
rule for damages in New York, 659.
arbitration bonds, 661, 662,
injunction bond, damages on, 664, 665.
consequential damages, when allowed, 666.
delivery bond, damages on, 567.
appeal bond, 668,
condition of the bond, 669.
damages, 669.
indemnifying bonds, 670.
damages, in case of a suit, 671. :
Supreme Court of New Hampshire on question of damages, 672.
replevin bond, 674.
damages, measure of, 675.
general rule of damages in case of replevin, 776.
when the verdict of the court will settle the question of damages, 675.
P.
PARTIES, :
plaintiff must in order to maintain his action have an interest in sub-
ject matter, 22.
parties at common law, 23, 27.
action at common law for torts must be brought in the name of the
party affected, 24.
the common law rule abolished, 23.
when the plaintiff may recover, 25.
the law does not notice trifles, 25.
individuals only responsible for voluntary acts, 25.
right of adjoining land owners, 25.
«municipal corporation not liable for failure to pertorm legislative and
govermental acts, 26.
the rights of the owner of the surface of land, 28.
defendants, 30.
infant, when he cannot be sued, 30.
joint torts, who held liable for. 31.
joint defendants, 31.
PARENT AND CHILD,
parent may give his child moderate correction, Sy.
PATENT LAWS,
the Government frequently grants patents, 310.
letters patent, 310,
INDEX. 685
PATENT LAWS—Continued.
damages in case of an infringement of the patent, how ascertained,
311, 313.
general rule for the assessment of damages, 312.
profits generally taken as the basis of estimating damages, 314.
in case of an infringement in the making only nominal damages can
be recovered, 315. .
equity rule for the assessment of damages, 316.
copyright, action lies for an infringement upon, 316.
the measure of damages, 318,
dramatic composition, etc., 319.
damages for the infringement of the right, 319.
trade marks, individuals protected in the use of, 320,
damages for using the same without the consent of the owner, 320.
the rule for the assessment of damages is the profits that defendant
has realized. 320.
PROMISSORY NOTES,
promissory notes and bills of exchange.
full compensatian for all loss sustained the rule of damages in case of
breach, 465.
remote damages not allowed, 465.
principal and interest the true measure of damages, 466, 467.
legal tender question, payment of note in depreciated currency, 468.
rate of interest fixed by the contract fixes the measure of recovery, 470,
rate of interest fixed by law governs in the absence of special agree-
ment, 471.
damage on note originated in one State and payable in another, 472.
suit On a note in one State made in another, rate of interest when
made governs, 473.
as a rule the law of the place where the contract is made will govern
the rate of interest, 474. \
place of performance considered, governs the rate of interest, 474.
interest forbidden by Jaw must be recovered, 476.
two kinds of money in the United States, 477.
power of Congress to make the promissory notes of the Government
a legal tender, decision, 477.
contract to pay gold and silver means to deliver so many groceries, 478.
general rule as to payment, 476.
rule in Indiana, 480.
general rules deducible for all the decisions, 481.
interest did not abate during the civil war, 482.
compound interest, when allowed, 483, 499.
note payable in salt, 484.
interest can be recovered after payment of principal, 485.
conflict of authorities, rule recommended, etc., 486, 487.
rule in Iowa, 488.
636 LAW OF DAMAGES.
PROMISSORY, NOTES—Continued.
coupon bonds du not draw interest, 489.
notes made payable in specific articles, 484, 490, 491.
Indiana and Wisconsin rule, 492,
interest, rate of in the different States, 493.
rights of parties to bill and notes to be determined by law of the place
where made, 494
exception where note or bill is drawn in one State and made payable
in another, the law of place of payment governs, 494.
bill and notes transferable, 495, 496.
PRINCIPAL AND SURETY,
surety defined, 497.
the execution of an agreement, 497.
lease of Deardorff v. Forsman consided, 499.
discharge of surety by conduct of the other parties, 506.
release, when will obviate as a discharge, 503, 504, 505.
construction of a contract of reléase, 506,
where the payee when he releases one may resue his right against the
other, it will be considered an agreement not to sue, 503, 504, 505, 506.
discharge of co-surety only discharges half the debt, 507.
relation of the parties after’ judgment remains the same, 508.
mortgage property stands as other property, 509.
surety discharged by releasing levy on property, 510.
release of lien on property discharges surety, 511.
surety when discharged by notice to sue, 511.
note signed for particular purpose and used for another, as a rule
void, 513.
the surety may recover by way of damages all money expended for the
principal, with lega: interest and costs, 514.
surety has no cause of action until he makes payment of the principal
debt 515, 516, 517.
guaranty defined, 518.
damages that he may recover, 521.
PERSONAL PROPERTY,
damage in case of « tailure to deliver personal property, 546.
full compensation for all loss the rule, 546.
when the price has not been paid the measure of damages is the differ-
ence between the contract price and the value of the property at the
time of delivery, 546, 548.
the reason for this rule, 546.
the States in which the highest market value of the property is consid-
ered as damages for failure to deliver personal property, 547.
Pennsylvania rule, 548.
where personal property is sold to supply a person for a sale contract,
the measure of damages, 549-552.
damages when goods are to be delivered at different times, 553-
INDEX. 637
PERSONAL PROPERT Y— Continued.
the rule in the case of Hadly v. Baxendale applie , 554, 555.
remote and speculative damages never allowed, 556.
the general rules deducted trom all the authorities, 557.
damages for failure to deliver stock thought by some to be different
from a failure to deliver other property, 558.
but the rule is the same in both cases, 558.
market value, the reason for its adoption as a standard, 559.
damage when the vendee fails to comply, difference between contract
price and market price, 560.
damage when there is a failure to take goods manufactured to order,
561, 562.
damages in case of a partial delivery, 563.
reduction of the rule to common sense, 566,
PRINCIPAL AND AGENT,
the right of a person to appoint an agent, 704.
who can appoint an agent, 704,
minors, married women, etc., cannot appoint an agent, 704.
who may act as agent, 705.
the law of principal and agent definitely settled, 906:
good faith required of the agent, 707.
the principal can recover all damages sustained by the misconduct of
his agent, 708.
remote and consequential damages not allowed, 709.
the principal remedies, 710.
PROXIMATE CONSEQUENCES, 6.
ER.
RECEIVER, DEFINED.
generally required to give bond, 677.
damages for breach of duty, 678.
ministerial officers bonds. ie
damages that may be recovered, 680.
* remote and speculative damages cannot be recovered, 681.
bonds on sale of liquor, 682.
measure of damages, 682.
REMOTE DAMAGES. 4, 6. :
the wrong-doer is responsible, not only for the first result, but for every
succeeding result, 6,
see Negligence.
difference between direct and remote cause, 44.
REPLEVIN,
at common law abolished in most of ‘the states, 280.
personal property can only be recovered in an action of replevin, 290.
land, and, ordinarilp, whatever is attached to it. cannot be recovered, 290.
what will be considered as personal property, 291.
fixtures, how determined, 292.
638 LAW OF DAMAGES.
REPLEVIN, Continued.
growing crops, when considered a fixture, 263. ’
damages, measure of differs in the different States, 294.
where property cannot be returned, its value the true measure of dam-
ages, 295.
where property returned is reduced in value, the measure of dam-
ages, 295.
Kansas rule, 295.
Nominal damages, when allowed, 297.
Exemplary damagss, when allowed, &c., 298.
the plaintiff’s damages will be estimated according to his interest, 299.
elements of damages, 300.
damages where property 1s not returned, 301.
damages where articles are of a peculiar value, 302.
damages for defendant where the court orders a return of the proper-
ty, 303.
\ Ss.
SCHOOL TEACHER,
when and how he may correct his pupils, 88.
SEAMAN,
when he may be chastised, 87.
SEDUCTION,
action for seduction at common law may be maintained by parent,
guardian, or other person, standing in loco parentis for the seduction
of a female, 110.
the damages, what they will embrace, 111.
SALES, (see Personal Property, sections 546 to 566.)
SERVICE AND LABOR,
division of the subject, 567.
case of breach of contract, the employe has two remedies, 568,
when he may sue on quantum meruit, 568.
readiness to perform, 568.
duty of the dismissed servant to hunt work. 569. .
the act of God, when an excuse for the non-performance of labor, 570.
when the employer has broken the contract, the employe in case of
suit may recover for all loss sustained, 570.
profits should be considered in assessing damages, 571,
the employe may recover in case of part perforniance to the amount of
the benefit the employer has received, 572.
but in order to recover, the work must have been accepted, 575.
what will be considered an acceptance, 574.
extra work, 575.
employer may recover what such work is worth, 575.
the rule allowing a recovery for the benefit the employer. may receive
from the labor discussed, 576.
it is called the liberal rule, 576, 577, 578.
INDEX. 639
damages where the employe is prevented by the act of the employer
from performing the labor,3579, 580.
damages where the employe fails to complete his job.
damages, general rule, 583, 585 586.
nts
TRESPASS, DEFINED, 148.
“ to real and personai property, defined, 149.
the general owner of property presumed to have possession, 150 151.
an officer who abuses his authority liable as a trespasser, 152.
the intention makes the wrong, 153,
case where persons are injured and have no remedy, 154.
damages, general rule, 155. —~
damages, for injury to animals, 156 158.
damages in case of injury to water privileges and water right, 159-162,
damages to land, 163-165.-—
consequential damages, 166.
division of damages, 167.
tenants’ damages, 168.
damages in case of injury to mines, 169,
TROVER, DEFINED,
the measure of damages the value of the property with interest. 278,
the true rule for the assessment of damages is the value of the property
at the time of: conversion, 278.
exception to the general rule for the assessment of damages at the value
of the property at the time of conversion, 278.
consequential damages. when allowed, 278.
conflict among authorities as to the true measure of damages, 280.
how the conflicting rules might be reconciled, 280.
the different rules owing perhaps to the different forms of action, 281.
compensation for the loss is the true rule, 282.
value of the property with interest is the measure of damages that
should be adopted, 283.
damages in case of gifts and articles of virtu, 284, 285.
the market value of the property not always considered the measure of
damages, 286.
damages for conversion of Pretium affectionis, 286.
good and bad faith, when considered, 289.
exemplary damages may under certain circumstances be recovered, 288.
thé general rules for the assessment of damages and exceptions consid-
ered, 288
TRADE MARKS,
persons protected in the use of, 320.
act of Congress, (unconstitutional), 320.
the measure of damages is the profit that the defendant has made, 320,
damages where the profits cannot be ascertained, 321.
See Patent Laws.
640 LAW OF DAMAGES.
TELEGRAPHING, its origin, 619. 3
its right to limit its responsibility by contract, 620.
its general powers to limit responsibilities, 621.
‘the gereral rule for limiting responsibility. 622, 626.
damages, full compensation for all loss, 618.
general rule of damages, 629.
consequential damages, wh n responsible for, 630.
responsible tor al] the consequences of negligence, 631.
damages for sending dispatches to ship owners, 624.
instances where consequential damages have been allowed, 524, 533,
; ; 534 535» 536.
when damages will be limited to interest, 637.
damages where company refuses to send messages, 638.
liability of different companies who transmit the same message, 639.
WATERCOURSES,
the right of a land owner to use the water on his premises, 343.
the owner of land on a stream of waterhas a right to use all the water
in the stream to the exclusion of those below him, 344.
the law sometimes makes a distinction between natural and artificial
wants. 345.
how and when water mav be used, 346.
title to subterranean streams, 347.
the owner of the surface ‘may destroy a subterranean stream, 347.
surface watercourse may be changed, 348.
the damages, 348.
profits that might have been realized from the use of water allowed
in some cases, 349
WARRANTY IN SALE OF PERSONAL PROPERTY, DEFINED, 522.
what is considered a wairanty, 524.
the purchaser must exercise common sense, 525.
implied warranty, 526.
rule of caveat emptor, 527.
warranty must be made betore the property is delivered, 528.
warranty in case of goods sold by sample, 529.
damages in case of breach of warranty, 530.
the difference between the value of the property andits value as war-
ranted, 530.
market value considered, 530.
exception to the general rule, 531.
consequential damages allowed, 531, 532, 533, 539) 540, 541, 542, 543.
damages in case of a breach of warranty of title, 535.
in sale of stocks warranted of certain value at a fixed time, 536.
damages where there is a breach of warranty in the sale of, diseased
animals, 537. 538.
general rule of damages in sale of animals diseased, 589.
articles manufactured for certain purpose warranted fit for such pur-
pose, 541, 542 :
damages, rule in England, 542.
rule in America, 543.
gains and losses to be considered, 543.
goods bought for a certain market, warranted fit for the same, 544.
price paid when considered, 514.
wrong-doer will not be permitted to apportion his damages, 7.
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