Brown v. Collins

53 N.H. 442 (1873)

Quick Summary

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Collins (the defendant) was waiting at a railroad crossing with his horse and wagon loaded with grain when his horses got frightened by a train and ran uncontrollably, causing damage to a stone post on Brown’s (the plaintiff) property. Mr. Brown, the owner of the land, filed a lawsuit against Collins for damages based on negligent conduct.

However, the court found insufficient evidence to prove Collins was negligent and dismissed the case, absolving Collins of any liability for the damages.

Rule of Law

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The defendant cannot be held liable if they did not act recklessly, unlawfully or if the harm was not a foreseeable consequence of their actions.

Facts of the Case

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Brown (plaintiff) owned a piece of land that had a stone post with a street light on it. The (defendant) Collins, was waiting at a railroad crossing on his horse wagon while it was loaded with grain being pulled by two horses.

The horses were suddenly frightened by the engine noise of the train, which made them uncontrollable for the defendant. As a result, Collins was separated from his horse wagon. The horses, along with the wagon, ran into Mr. Brown’s property, causing damage to the stone post. As a result, the plaintiff filed a lawsuit against the defendant.


Issue Icon

Should Collins be held accountable for the damages his horses caused to Brown’s property?

Holding and Conclusion

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Because it has not been proven that the defendant was negligent in allowing his horses to cause the damage, he is not liable for the costs associated with the repair. The court dismissed the case because the plaintiff failed to provide sufficient evidence of the defendant’s negligence.

Reasoning and Analysis

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The court determined that Collins is not liable for the damages to Brown’s property due to the plaintiff’s failure to establish sufficient evidence of the defendant’s negligence. This is in line with established legal principle, which holds that a defendant can only be held liable for damages if it is proven that their negligence caused the damages.

The court also applied the principle that a defendant cannot be held liable if they did not act carelessly or unlawfully or if the harm did not result from an act for which the defendant knew or should have known that the damage was a necessary, likely, or natural consequence.

This is consistent with case law on negligence and causation, which mandates that the plaintiff must prove that the defendant’s actions were a direct and proximate cause of the harm suffered.

Relevant FAQs of this case

What are the basic elements of a negligence claim?

If the plaintiff is to win a negligence case, he or she must prove four things to the court to show that the defendant (the party at fault) was negligent.

  • Duty: The defendant owed the plaintiff a legal duty given the circumstances.
  • Breach of Legal Duty: By doing something illegal or failing to do something illegal, the defendant has breached this legal obligation.
  • Causation: The plaintiff was harmed due to the defendant’s actions (or inaction); and
  • Damages: The plaintiff suffered damages because of the defendant’s misconduct.

The courts strictly adhere to the doctrine of res ipsa loquitur (Latin for “the thing speaks for itself”). Thus, the court can examine the evidence at hand and decide whether or not the cause of the loss is patent.

The defendant can also be considered negligent if the burden of taking safeguards to protect the plaintiff was less than the plaintiff’s damage multiplied by the likelihood of its occurrence.


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