Byrne v. Boadle, 159 E.R. 299 (1863)
FACTS: Byrne was walking in a public street past Boadle’s shop. A barrel from Defendant’s shop fell onto Byrne. As a result, Byrne was injured and incurred medical expenses.
ISSUE: Whether Byrne (Plaintiff) may rely upon the doctrine of res ipsa loquitur to infer Boadle (Defendant) is negligent and responsible for the barrel of flour dropping onto him.
RULE: Negligence requires a showing that defendant owed a duty of care to Plaintiff, defendant breached duty of care, Plaintiff was injured, and Defendant’s negligence resulted in Plaintiff’s injuries. Res ipsa loquitur applies if a defendant had sole control of the object that caused the injury. Second, the accident would not have occurred but for defendant’s negligence.
ANALYSIS: Defendant had the duty to maintain their barrels and to ensure they did not roll out. The Court reasoned that a barrel could not roll out on its own without Defendant being negligent.
CONCLUSION: Yes. Plaintiff may rely upon the doctrine of res ipsa loquitur to infer Defendant is negligent and responsible for the barrel of flour dropping onto him.