Larson v. St. Francis Hotel — a famous case about a falling chair

mid-cities personal injury lawyer

While traveling in San Francisco on business I took an opportunity to snap a picture of the St. Francis Hotel, now the Westin St. Francis Hotel, at Union Square. This hotel has a famous reputation among law students, much like this house in Cleburne, Texas.

Most law students learn the law using the same set of cases. One particular case involving this hotel teaches a legal principle in many first year tort classes. The case is Larson v. St. Francis Hotel (83 Cal. App. 2d 210, 188 P.2d 513, 1948 Cal. App.). It helps explain an important element of the legal principle known as res ipsa loquitur. Res ipsa loquitur is a Latin phrase that means “the thing speaks for itself”. It establishes the negligence of a party when no witnesses exist to explain how an injury occurred; but only one explanation is probable.

Specifically, res ipsa loquitur applies when (1) an accident occurs; (2) the cause of the accident was an object under the exclusive control of the defendant; (3) and had the defendant exercised ordinary care over the object, under ordinary circumstances, the accident would not occur. Res ipsa loquitur commonly applies when people suffer injury by falling objects. Man-made objects rarely fall out of the sky under ordinary care.

A well known lawsuit and legal premise

In Larson v. St. Francis Hotel, the court presents clear analysis of the second element of res ipsa loquitur. Larson visited the St. Francis Hotel on V-J Day and unsurprisingly there was quite a bit of celebration that day. Larson walked out from under the marquee and a large stuffed chair fell on him, injuring him. In San Francisco hotels windows commonly open on high floors. I stayed at a different hotel and even the windows at the top of that hotel, on the twenty-first floor, fully opened. No painting the windows closed. So injured Larson sues the hotel claiming res ipsa loquitur as the legal theory of why the hotel was liable for his injuries.

The appellate court disagreed with the application of res ipsa loquitur. For res ipsa loquitur to apply the object causing the accident must be under the exclusive control of the defendant. It does not apply if there is divided liability between multiple parties resulting in multiple possible causes for the injury and not all of those possible causes attributable to the defendant. Here, the court reasoned that the furnishings in hotel rooms are under the control of the guests within the individual rooms and even if the hotel had taken ordinary care it would not prevent a guest from throwing a chair out of a window. As a result, Larson lost his claim against the hotel, at least as far as his res ipsa loquitur claim was concerned.

Res ipsa loquitur

Res ipsa loquitur is not the only way to bring a claim for an injury caused by a falling object. Larson may have had other negligence-based claims available against the hotel and certainly claims for intentional and/or negligence claims against various guests of the hotel although it would have been difficult to figure out who really tossed out the chair. Larson is taught in law schools because the unique facts make it a clear illustration of the exclusive control element of res ipsa loquitur. More common injuries from falling objects occur in situations where this particular legal theory is not the strongest claim and the identity of involved parties are much more obvious.

While the St. Francis Hotel case is a somewhat unique case, these kinds of injuries regularly occur in less interesting places. Injuries from falling objects are alarmingly more common in retail stores than one might imagine. Many retail stores, such as Wal-Mart and Auto Zone, display large and heavy objects on the top shelf of display units where they are prone to fall off or accidentally get pushed off by another customer. These heavy objects can strike individuals in the head, neck and shoulders.

The injuries caused by these falling objects can be severe and permanent because the injuries occur at the spine and skull. These types of injuries can also occur in other places. They are not limited to retail stores. Airplanes are another place where similar injuries can occur due to luggage falling out of the overhead bins either during turbulence or as people are trying to deplane and remove their carry-on luggage.

Injury claims in Texas

If you are injured due to falling objects then it is extremely important that you obtain medical care and allow a physician to review your condition to assess whether any bone, nerve, or soft tissue injuries have occurred. Sometimes injuries do not immediately develop serious pain, such as inflammation that grows worse with time; but a physician can properly assess your injuries and determine whether you need medical care or what steps to take if pain or limits on your range of motion develop.

It is also important to obtain medical care early on to protect your possible legal claims. It shows you had an injury or concern about an injury if you obtain medical care right away. The longer you wait the less it will appear you developed an injury from the falling object. That will make recovering for your injury more difficult.

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