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Keywords

defendantliabilityduty of care
defendantliabilitytrialtestimonysustainedduty of care

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J.I. Case Threshing Mach. Co. v. Haynes, 178 Ky. 644, 199 S.W. 786

Facts

Haynes, an outside agent for the J. I. Case Threshing Machine Company, was injured while assisting in the operation of a freight elevator that had been rendered unsafe due to a missing cross-piece. He was in the building to meet the local manager, E. S. Reeves, and, at Reeves' request, attempted to help operate the elevator. The elevator tilted and dumped a load of pumps on him, causing his injuries. The defendants contended that Haynes acted voluntarily and against their instructions.

On the morning he was injured, according to his testimony, he went to the building to get Reeves who was to go out in the country with him to see about selling automobiles, and while he was in the building waiting for Reeves a load of pumps was put on the elevator which was standing at the first floor. It appears that the elevator was operated by pulling a rope, and he testified that by the direction and at the request of Reeves, who was the manager of the machine company in charge of the building and its business at Lexington, he undertook to assist him in raising by means of the rope the elevator to the second floor of the building, where it was intended to discharge the load, and while engaged in this work, and about the time the elevator reached the second story, it tilted over, causing the pumps to slide off and fall on him, whereby he sustained the injuries complained of.

Issue

Was Haynes acting as a volunteer or under the direction of the company's manager, and did the company owe him a duty of care?

The issue as to whether Haynes was a volunteer or occupied the relation of servant was also submitted to the jury, and although there was sharp dispute on this question, there was sufficient evidence to sustain the finding of the jury that Haynes occupied the relation of a servant, and not a volunteer.

Rule

The court instructed the jury that if they believed Haynes was directed by Reeves to assist with the elevator and that the elevator was known to be defective, they should find for Haynes. Conversely, if Haynes acted on his own accord, they should find for the machine company.

The trial court instructed the jury, in substance, that if they believed Reeves was the general manager of the machine company, in charge of its warehouse and business, and that he directed Haynes to assist in the operation of the elevator, and that Haynes, in obedience to his discretion, did assist him, and that at the time the elevator was defective and dangerous to operate, and this fact was known to the defendants, or by the exercise or ordinary care could have been known to them, and by reason of its defective condition it was caused to tilt over and dump the load on Haynes, they should find for him against the machine company.

Analysis

The court analyzed the evidence to determine whether Haynes was a volunteer or acting under the direction of Reeves. The jury was instructed to consider the authority of Reeves and whether Haynes was assisting in a manner that would establish a servant-employer relationship. The court noted that there was sufficient evidence to support the jury's finding that Haynes was not a volunteer.

Really, the questions in the case, as we look at them, are purely of fact, and while there was sharp dispute in the evidence on the vital issue as to whether Haynes was a volunteer or servant, there was enough to sustain the contention of Haynes, and the judgment is affirmed.

Conclusion

The court affirmed the judgment in favor of Haynes, concluding that there was enough evidence to support the jury's finding that he was acting under the direction of Reeves, thus establishing the company's liability.

The court affirmed the judgment in favor of Haynes, concluding that there was enough evidence to support the jury's finding that he was acting under the direction of Reeves, thus establishing the company's liability.

Who won?

Richard Haynes prevailed in the case because the jury found that he was acting under the direction of the company's manager, which established the company's duty of care.

Richard Haynes prevailed in the case because the jury found that he was acting under the direction of the company's manager, which established the company's duty of care.

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