Morris v. Platt
32 Conn. 75 (1864)
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Rule of Law:
A person engaged in a lawful act, such as self-defense, is not liable for injuries accidentally and unintentionally inflicted upon an innocent third party unless the injured party proves the act was done without due care.
Facts:
- The defendant, Platt, was assailed by several individuals.
- Platt believed the nature of the attack put him in imminent peril of losing his life or suffering extreme bodily harm.
- To defend himself from his assailants, Platt fired a pistol.
- The plaintiff, Morris, claimed he was an innocent bystander and not involved in the assault on Platt.
- Two shots fired by Platt struck and wounded Morris.
Procedural Posture:
- Morris sued Platt in a trial court for trespass, specifically assault and battery.
- At trial, Platt argued self-defense and requested a jury instruction that a reasonable belief of danger was sufficient justification.
- Morris requested an instruction that Platt was liable for his injuries if he was an innocent bystander, regardless of whether Platt was lawfully defending himself.
- The trial court denied Platt's requested instruction and granted Morris's instruction.
- The jury returned a verdict in favor of the plaintiff, Morris.
- Platt appealed the verdict to the state's highest court, alleging error in the trial court's jury instructions.
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Issue:
Is a person who is lawfully exercising their right to self-defense civilly liable for injuries unintentionally and accidentally inflicted upon an innocent bystander, without proof that the person acted with negligence or a lack of due care?
Opinions:
Majority - Butler, J.
No, a person lawfully exercising self-defense is not liable for accidentally injuring a bystander unless the act was done without due care. The trial court erred in two ways. First, it failed to instruct the jury that self-defense is justified if a person has a reasonable belief of imminent peril, even if that belief turns out to be false. Second, and more central to the case, the court incorrectly instructed that a person is strictly liable for accidentally injuring a bystander during lawful self-defense. The proper legal standard for unintentional injuries resulting from a lawful act is negligence, not strict liability. The foundation of liability in such cases is a lack of due care, and the burden is on the plaintiff to prove that the defendant acted with negligence or folly under the circumstances. The court extended the principle from cases of consequential injury (actions on the case) to cases of direct injury (actions in trespass), holding that the form of the action should not change the underlying basis for liability, which is fault.
Analysis:
This decision is significant for its rejection of the traditional common law rule that imposed strict liability for direct, albeit unintentional, harms under the writ of trespass. By holding that negligence is the basis for liability for accidental injuries caused during a lawful act, the court helped unify tort law around the principle of fault. This case establishes that even when an innocent bystander is harmed, the actor is not liable unless they failed to exercise reasonable care under the circumstances. This shifts the legal analysis from merely determining causation to assessing the blameworthiness of the defendant's conduct, and places the burden on the plaintiff to prove that the defendant's conduct fell below the standard of due care.
