## Facts

- Ryan owned and occupied a dwelling house in Syracuse, New York.
- The New York Central Railroad operated a railroad with a wood-shed and stored wood near the track.
- On July 15, 1854, a railroad locomotive, due to negligent management or defective condition, ignited the railroad’s wood-shed and wood supply.
- Ryan’s house was about 130 feet from the wood-shed; it caught fire from heat and sparks and was destroyed despite efforts to save it.
- Multiple other buildings also burned as the fire spread.
- Ryan sued the railroad for the value of his house and its contents, alleging negligence caused the loss.

## Issues

1. Whether negligence that ignites a fire on the defendant’s premises makes the defendant liable for destruction of a neighboring house burned after the fire spreads beyond the defendant’s property.
2. Whether the spread of the fire to the plaintiff’s house was a proximate consequence of the railroad’s negligence or a remote, noncompensable consequence.

## Decision

- The Court of Appeals affirmed the nonsuit for the railroad.
- The court held the destruction of Ryan’s house was a remote consequence, not proximately caused by the negligent ignition of the wood-shed fire.
- The railroad was liable, at most, for the direct destruction on its own premises, not for losses attributable to the fire’s subsequent spread.

## Legal Principles

- Negligence liability extends to damages that are the proximate results of the defendant’s acts, not remote damages.
- Proximate damages are those that are the natural or necessary consequences of the act and are ordinarily to be anticipated.
- Where a claimed harm depends on a chain of contingent circumstances (e.g., conditions affecting a spreading fire), the resulting losses may be treated as too remote as a matter of law.
- Proximate cause functions as a limiting rule on liability to avoid imposing effectively unlimited responsibility for widespread losses.

## Conclusion

The court limited negligence liability for a spreading fire by treating destruction of a neighboring house, burned after the fire escaped the defendant’s property, as a remote consequence outside proximate cause, and it affirmed dismissal of the plaintiff’s claim.


Ryan v. N.Y. Cent. R.R. Co., 35 N.Y. 210 (N.Y. 1866)