Williams v. Hays

This was the second appeal in the shipwreck litigation. Hays (defendant), captain and part owner, had battled a three-day storm with little food or sleep, taken strong medicine, and refused two tugboats' offers to tow the damaged ship, which then wrecked. After the first appeal reversed a defense verdict, the case returned to the trial court, where Hays raised whether his incapacity resulted solely from his exhausting efforts to save the ship. The trial court directed a verdict for the plaintiff owners, including Williams (plaintiffs), and Hays appealed.

Whether a person who became incapacitated solely through his own reasonable efforts to save the ship can still be found to have met the reasonable-person standard of care.