Sheldon Against the Hudson River Railroad Co.

Summary

The New York Court of Appeals reversed the trial court's nonsuit and ordered a new trial, holding that the plaintiff's circumstantial evidence of engine sparks was admissible and that the burden shifted to the railroad to rebut the inference of liability. The court emphasized that, under the circumstances, the onus could fall on the defendant to prove the fire was not caused by its engines. A concurrence agreed the evidence was competent but cautioned that negligence cannot be inferred solely from the fire. The dissent disagreed with the majority's approach.