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Vincent v. Lake Erie Transportation Co.

Minnesota Supreme Court
124 N.W.221 (Minn. 1910)



R.C. Vincent and others (Vincent) (plaintiffs) owned a dock in Duluth. On November 27, 1905, Lake Erie Transportation Co. (Erie) (defendant) anchored its boat to Vincent’s dock to unload the cargo. A violent storm hit that prevented boats from leaving the harbor for two days. During that time, Erie deliberately kept its boat anchored to Vincent’s dock to prevent it from drifting away. It is undisputed that doing so was a reasonable exercise of ordinary care given the severity of the storm. However, strong winds repeatedly knocked the boat up against Vincent’s dock, causing damage. Vincent sued Erie to recover damages, and the jury awarded Vincent $500. Erie appealed, arguing that it cannot be held liable for the damage to the dock because it acted with due care under the circumstances.

Rule of Law


Holding and Reasoning (O’Brien, J.)

Dissent (Lewis, J.)

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