## Facts

- The brig *Emily T. Sheldon* sailed from Boothbay, Maine, to Annapolis, Maryland, carrying ice and encountered a severe storm after about sixteen hours at sea.
- The vessel was wrecked on Peaked Hill Bar near Provincetown, Massachusetts, causing loss to owners including Parsons and Loud, who held a one-sixteenth interest.
- Phoenix Insurance Company paid the insured loss and its assignee, Paul Williams, sued the brig’s master and part owner, William Hays, alleging the wreck resulted from Hays’s negligence.
- Hays denied negligence and asserted that, at the time of the wreck, illness, exhaustion, and quinine rendered him mentally incompetent and not responsible for his conduct.
- Evidence indicated Hays had been under extreme strain with little food or sleep while attempting to manage the storm and save the vessel.
- The trial court ruled that insanity was not a defense as a matter of law and directed a verdict for Williams, refusing to submit to the jury questions about the cause of Hays’s incapacity and whether the mate should have assumed command.
- The Appellate Division affirmed; Hays appealed.

## Issues

1. Whether mental incapacity or insanity excuses civil liability for negligence that injures the property interests of others.
2. Whether a defendant may avoid negligence liability for acts committed while incapacitated when the incapacity was brought about by the defendant’s own prior negligence.
3. Whether the trial court erred by directing a verdict rather than submitting to the jury disputed questions about (a) the cause and extent of the master’s incapacity and (b) the mate’s knowledge and conduct in failing to take command.

## Decision

- The Court of Appeals of New York reversed and ordered a new trial; one judge dissented.
- The court reaffirmed the general rule that insanity does not excuse a person from civil liability for torts, including negligence.
- The court rejected any rule allowing a defendant to escape liability for negligent acts on the ground that a negligent course of conduct caused the defendant’s later incapacity.
- The court held, however, that the record presented factual disputes on causation and fault allocation, including the source of Hays’s incapacity and the mate’s duties once the master appeared incompetent.
- Because different inferences could fairly be drawn, the trial court erred in removing these issues from the jury by directing a verdict for the plaintiff.

## Legal Principles

- An insane person is generally liable in tort to the same extent as a sane person.
- A defendant cannot use a mental or physical condition brought about by the defendant’s own wrongful or negligent conduct as a defense to negligence liability.
- When evidence permits competing inferences on reasonableness, causation, and responsibility among actors, those questions are for the jury and should not be resolved by directed verdict.
- In maritime operations, a mate cannot casually supplant the master without risk of insubordination, but may be required to assume control if the master’s incompetency becomes so apparent that a prudent officer would act.

## Conclusion

The court held that insanity does not generally excuse civil negligence and rejected any defense based on incapacity produced by the defendant’s own negligent conduct, but reversed because the jury should have decided contested facts about the cause of the master’s condition and whether the mate’s failure to take command affected negligence and causation.


Williams v. Hays, 157 N.Y. 541, 52 N.E. 589 (N.Y. 1899)