Tingle v. C., B. & Q. R.
14 N.W. 320, 60 Iowa 333 (1882)
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Rule of Law:
The violation of a statute, such as a law prohibiting labor on Sunday, does not create civil liability for an injury that occurs during the violation unless the unlawful act itself is the proximate cause of the injury.
Facts:
- A railroad company operated one of its trains on a Sunday.
- The operation of the train on Sunday violated section 4072 of the Code, which prohibited labor on that day.
- The train struck and killed a cow at a public highway crossing.
- At the time of the incident, the cow was lawfully running at large.
- There was no negligence on the part of the railroad or its employees in the operation of the train; the incident was an accident.
Procedural Posture:
- The owner of the cow (plaintiff) sued the railroad company (defendant) in a trial court to recover damages for the loss of the animal.
- The defendant railroad company filed a demurrer to the plaintiff's petition, arguing that the facts alleged did not constitute a valid legal claim for liability.
- The trial court overruled the defendant's demurrer, effectively allowing the plaintiff's case to proceed.
- Because the amount in controversy was small, the trial court certified a specific legal question to the state's highest court for review.
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Issue:
Is a railroad company civilly liable for killing a cow while operating its train on a Sunday in violation of a statute, when the company was not otherwise negligent in the train's operation?
Opinions:
Majority - Day, J.
No. A defendant's violation of a statute does not create civil liability for injuries inflicted during the violation unless the unlawful act itself proximately caused the injury. The court reasoned that if a plaintiff's own violation of a Sunday law does not bar them from recovering for an injury (as established in Schmid v. Humphrey and Sutton v. The Town of Wauwatossa), then a defendant's violation of the same law should not, by itself, create liability. Although the injury would not have happened 'but for' the train's operation on Sunday, the mere timing of the act was not the proximate cause. The proximate cause was an unavoidable accident, not the statutory violation. The only liability incurred for violating the Sunday labor law is the fine prescribed by the statute itself, not civil damages for an unrelated accident.
Analysis:
This decision solidifies the critical distinction between a statutory violation and tort liability by emphasizing the element of proximate cause. It establishes that a defendant's unlawful conduct must have a direct causal link to the plaintiff's harm to create civil liability. This prevents the imposition of what would be, in effect, strict liability for any accident that occurs during the commission of an unrelated, minor statutory offense. The ruling reinforces the principle that tort law aims to compensate for harms caused by wrongful conduct, not simply to punish any and all unlawful acts through civil damages.
