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Law School Case Brief

Christianson v. Chi., S. P., M. & O. R. Co. - 67 Minn. 94, 69 N.W. 640 (1896)


The law is that if the act is one which the party ought, in the exercise of ordinary care, to have anticipated was liable to result in injury to others, then he is liable for any injury proximately resulting from it, although he could not have anticipated the particular injury which did happen. Consequences, which follow in unbroken sequence, without an intervening efficient cause, from the original negligent act, are natural and proximate; and for such consequences the original wrongdoer is responsible, even though he could not have foreseen the particular results which did follow.


Plaintiff employee was awarded damages against defendant railroad for personal injuries incurred when he fell off of a handcar due to the rapid approach of another handcar from the rear, which was negligently operated by employees who had been drinking. The trial court denied the railroad's motion for new trial despite the defenses interposed that defendant was not guilty of any negligence and that the plaintiff was guilty of contributory negligence.


Did the trial court err in denying the railroad's motion for a new trial in plaintiff employee's negligence action?




The court affirmed the trial court's order that denied the railroad's motion for a new trial following entry of a verdict in favor of the employee for damages against the railroad. The court found that sufficient evidence supported the jury's findings that the injured employee was not contributorily negligent, that the other employees were negligent in failing to keep a safe distance between the handcars, and that the action was not settled by an accord and satisfaction. The court rejected the contention that the employee's injuries were not proximately caused by the other employees' negligence because they could not have reasonable anticipated that the employee would fall from the car. The court explained that an original wrongdoer was responsible for the consequences that followed in an unbroken sequence from the original negligent act, without an intervening efficient cause, even though the wrongdoer did not anticipate the particular injury that happened. Under this rule, the court found it clear that the negligence of those employees on the rear handcar was the proximate cause of the injured employee's damages.

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