Anderson v. Minneapolis, St. Paul & Sault Ste. Marie Railway
146 Minn. 430, 179 N.W. 45 (1920)

  • Anderson’s property was burned in a fire. He sued Minneapolis for negligence.
    • Anderson argued that the fire was set by a train owned by Minneapolis, so they were responsible for the damage.
    • However, Minneapolis argued that there were other fires burning in the area at the time, and perhaps one of those was the cause of Anderson’s damage.
      • If Anderson’s property was damaged by a number of fires, then the damage would have occurred even if Minneapolis’ train wasn’t involved, so Minneapolis is not liable. (See Cook v. M., St. P. & S.S.M. Ry. Co. (98 Wis. 624, 74 N.W. 561)).
      • Basically, Minneapolis argued that this case doesn’t meet the but for standard, as in, “Anderson wouldn’t have been damaged but for Minneapolis’s negligence.”
  • The Trial Court found for Anderson. Minneapolis appealed.
    • The jury was instructed that if the Minneapolis train was “a material or substantial element in causing Anderson’s damages,” then Minneapolis was liable.
  • The Appellate Court affirmed.
    • The Appellate Court decided that in a case like that, all of the people who caused a fire would be jointly and severally liable.
  • In this case, the traditional but for test doesn’t seem very just. You have multiple negligent defendants who all started fires, and they all claim that even if they weren’t negligent Anderson still would have been damaged so therefore there’s no liability.
    • The Court felt that somebody should be liable for Anderson’s damage.