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Anderson v. Minneapolis - S. P. & S. S. M. R. Co., 146 Minn. 430, 179 N.W. 45 (1920)

Rule:

One who negligently sets a fire is not liable if another's property is damaged, unless it is made to appear that the fire was a material element in the destruction of the property. If a fire set by the engine of one railroad company unites with a fire set by the engine of another company, there is joint and several liability, even though either fire would have destroyed plaintiff's property. But if one of the fires is of unknown origin, there is no liability. Minn. Gen. Stat. § 4426 (1913) leaves no room for the application of a rule which would relieve a railroad company from liability under such circumstances.

Facts:

Plaintiff Jacob Anderson owned property near defendant Minneapolis Railway Company's tracks. Anderson sued Minneapolis Railway and Director General of Railroads for damages caused by a fire alleged to have been caused by sparks from one of Minneapolis Railway's locomotive engines that spread until it reached Anderson’s land, where it destroyed some of his property. The fire started in a bog near Anderson’s land and smoldered there for several months, when it flared up and burned his property shortly before it was reached by one of the great fires sweeping through the area that day. The jury returned a verdict for Anderson. Minneapolis Railway appealed the judgment.

Issue:

Was defendant Minneapolis Railway Company liable for the damages to plaintiff's Anderson’s property caused by a fire alleged to have been caused by sparks from one of the railway's locomotive engines? 

Answer:

Yes

Conclusion:

The state supreme court affirmed the judgment because the trial court did not abuse its discretion in allowing plaintiff Anderson to amend the complaint to conform to proof at trial. Moreover, the trial judge's instructions to the jury in the absence of counsel were correct statements of law, and the trial court was not obliged to notify counsel before responding to the jury's question. The Court also held that defendant Minneapolis Railway cannot escape liability for a fire started by one of its engines by showing that the fire united with another of no responsible origin and that Anderson's property was destroyed by the combined fires, if it appears that the railroad fire was a material element entering into the destruction of the property.

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