Hoyt v. Jeffers
Michigan Supreme Court
30 Mich. 181 (1874)
Relevant factsFree
Jeffers (defendant) owned a sawmill near Hoyt's (plaintiff) hotel, and the mill's chimney regularly emitted sparks. When Hoyt's hotel burned down with no witnesses to how the fire started, Hoyt introduced evidence that sparks had previously escaped the chimney, causing prior fires (including at the hotel itself) and burning holes in nearby clotheslines, to support his theory that mill sparks caused this fire too. Jeffers objected that the chimney had since been raised and modified, but the jury found for Hoyt; Jeffers appealed.
IssueFree
Whether a jury may consider and base its decision upon circumstantial evidence of causation when no direct evidence has been introduced.