Carolina C. & O. Ry. et al. v. Hill
Supreme Court of Virginia
119 Va. 416 (1916)
Elkanah Hill (plaintiff) owned a farm damaged during a period when both Carolina, Clinchfield & Ohio Railway (Carolina) (defendant) was constructing a nearby railroad and Yellow Poplar Lumber Company was separately removing lumber from the area; Hill sued only Carolina, and a jury awarded him $2,000. Carolina argued on appeal that Yellow Poplar's activities caused most of the damage and that Carolina should be liable only for damage it specifically caused, not the entire loss.
Whether, if there are several concurrent negligent causes of a loss and the effect of each cause is not separable, but each cause was sufficient to produce the entire loss, all parties are jointly and severally liable for the entire loss.