Katko v. Briney

Mr. and Mrs. Briney (defendants) owned a vacant farmhouse plagued by years of break-ins, so Mr. Briney rigged a shotgun spring-gun trap in a bedroom, aimed to fire at an intruder's legs when the door opened; there was no visible warning of the trap. Katko (plaintiff), who believed the house was abandoned, entered to collect old bottles as antiques, opened the bedroom door on a return visit, and was struck and seriously injured by the shotgun blast. A jury awarded Katko compensatory and punitive damages, and the trial court denied the Brineys' post-trial motions.