Mason v. Hoyle
Connecticut Supreme Court
56 Conn. 255, 14 A. 786 (1888)
- Written by Penny Ellison, JD
Facts
Charles Mason (plaintiff) operated a saw and grist mill using power obtained via a waterwheel run by a small dam and pond. Upstream, James Hoyle (defendant) operated a woolen mill, also supplied with water from a small dam on the stream and a pond but also through steam power. For many years, the flow of the river was sufficient to power both mills except in dry seasons. In 1881, Hoyle enlarged the pond, diverting almost all of the natural flow of the river to fill the pond. Subsequently, during the summer months when flow was low, Mason did not have sufficient water available to power his mill. Additionally, when the enlarged pond reached capacity and Hoyle switched from steam power to water, the released water overflowed Mason’s pond, running to waste. The predictable seasonality of the flow meant that there was insufficient water in the summer to serve both uses; thus, when Hoyle detained the water in the dry season, this denied Mason the use of his mill. It took five days of water diversion into the reservoir to run Hoyle’s equipment for only five hours. Because the seasonal water scarcity was regular and anticipated and Hoyle had installed machinery that required an amount of power that was greatly disproportionate to the capacity of the stream in the dry season, Hoyle could operate his mill using water power only for short and intermittent periods. Mason sued Hoyle, arguing that Hoyle’s diversion of the water and detainment for long periods of time was an unreasonable use of the stream.
Rule of Law
Issue
Holding and Reasoning (Loomis, J.)
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