Minn st paul sault ste marie rwy 179 nw 45 minn 1920

See Anderson v. Minn.
St. Paul & Sault Ste. Marie Rwy. , 179 N.W. 45 (Minn. 1920) ; accord . Restatement (Third) of
Torts: Phys. & Emot. Harm §§ 26-27]
Example :
A defendant negligently starts a fire in an arid, windy climate. Purely natural forces produce
another fire in the same general area. The wind drives both fires, so that they converge
upon the plaintiff’s barn at the same time. The barn burns to the ground. In the inevitable
lawsuit, the defendant argues that he is not liable, because the but-for test is not met—that
is to say, even if the defendant had not negligently started a fire, the barn would have
burned down anyway because of the other fire that resulted from natural forces. The
defendant is correct that the but-for test is not satisfied here. However, the defendant’s

conduct will nonetheless be deemed to be the actual cause of the damage to the plaintiff’s
barn under the substantial factor test. The defendant’s fire and the natural fire both
converged simultaneously on the barn. Each fire, standing alone, was sufficient to burn the
barn down. Because of the convergence of the fires, it is impossible to tell which fire caused
what portion of the damage. Finally, it is clear that the defendant’s fire was a substantial
factor in burning the barn down, since the defendant’s fire would have burned the barn
down even without the natural fire. Hence, the defendant will be responsible for 100
percent of the damage to the barn.
[This example is adapted from Anderson v. Minn. St. Paul & Sault Ste. Marie Rwy. , 179 N.W.
45 (Minn. 1920) ]
Concurrent Causes Doctrine
The concurrent causes doctrine applies when two elements are satisfied: (1) multiple acts
or forces combined to cause the plaintiff’s harm, and (2) neither act or force, by itself,
would have been sufficient to cause the harm. [ See Restatement (Third) of Torts: Phys. &
Emot. Harm § 26, cmt. c, i, illus. 4] Where each distinct act or force is the result of a different
person’s negligence, then each negligent party may be held liable.
Example :
A teenage driver negligently swerves his car into oncoming traffic. A trucker sees the
teenager’s car coming and swerves to avoid the teenager. However, the trucker is negligent
in doing so and strikes a pedestrian with his truck. This inflicts grievous and permanent
injuries upon the pedestrian. This is a prime case for application of the concurrent causes
doctrine. Neither the negligence of the teenager nor the negligence of the trucker would
have caused the pedestrian’s injury standing alone. However, both forces combined to cause
the pedestrian’s injury. The teenager’s negligent driving caused the trucker to swerve to
avoid the teenager, and the trucker’s negligence in avoiding the teenager caused the trucker
to strike the pedestrian. Hence, both the teenager and the trucker will be held liable for the
pedestrian’s injuries.