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Law School Case Brief

Vincent v. Lake Erie Transp. Co. - 109 Minn. 456, 124 N.W. 221 (1910)


If during a storm the defendant enters a harbor, and while there becomes disabled and is thrown against the plaintiffs' dock, the plaintiffs cannot recover. Again, if while attempting to hold fast to the dock the lines part, without any negligence, and the vessel is carried against some other boat or dock in the harbor, there would be no liability upon her owner. But where those in charge of the vessel deliberately and by their direct efforts hold their vessel in such a position that the damage to the dock results, and, having thus preserved the ship at the expense of the dock, her owners are responsible to the dock owners to the extent of the injury inflicted.


Plaintiffs R.C. Vincent and another owned a wharf in which ships docked to unload cargo. Defendant Lake Erie Transportation Company owned a ship that docked at plaintiffs' wharf during a storm. During the storm, plaintiffs' wharf was damaged by defendant's ship. Plaintiffs brought an action against defendant in Minnesota state court to recover for the damages to their wharf. The trial court denied defendant's motion for a directed verdict and entered judgment in favor of plaintiffs. The trial court denied defendant's subsequent motion for a new trial. Defendants appealed.


Were plaintiffs entitled to recover compensation for damages to their wharf?




The state supreme court affirmed, reasoning that the damage to plaintiffs' wharf was not caused by an act of God, which would have excused defendant's liability. Rather, plaintiffs' injury was inflicted because defendant prudently and advisedly availed itself of plaintiff's property for the purpose of preserving its own more valuable property. Thus, plaintiffs were entitled to compensation for the injury done.

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