Patten v. Halsted

1 N.J.L. 277 (1795)

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Patten v. Halsted

New Jersey Supreme Court
1 N.J.L. 277 (1795)

JC

Facts

Patten (plaintiff) had sought the arrest of multiple parties, and Halstead (defendant), then the sheriff, arrested Freeman pursuant to the writ that Patten had obtained. Patten subsequently obtained a judgment against Freeman for £1,526 19s. 6d. But Freeman then escaped from Halstead’s custody, which caused Patten to bring this suit against Halstead, alleging in the alternative that Halstead was liable for Freeman’s escape voluntarily or negligently. Halsted moved to dismiss the case, arguing that no requirement of any special bail existed. Halsted also argued that he had taken every precaution possible and acted rigorously in guarding Freeman but that Freeman’s escape had come via unforeseen circumstances that Halsted could not have prevented. Under English common law, any escape not occasioned by an act of God or public enemies was considered a negligent escape, with the law allowing no excuse for why a sheriff failed to keep a prisoner, akin to the application of strict liability. This rule existed because not to hold the sheriff liable would have been to invite collusion between sheriff and prisoner and make innocent third parties constantly watch the sheriff to ensure that the sheriff was performing his duties. In light of this instruction, the jury heard the case, found for Patten, and awarded Patten damages of the full £1,526 19s. 6d. Halsted then filed a motion for a new trial, arguing that the English law was not properly applicable, as the sheriff was responsible for building and repairing the jail in England, but that the jails were built and maintained by the local government in America.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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