San Juan Light & Transit Co. v. Requena

Background

A widow sued after her husband was killed by an electric shock while adjusting an incandescent light in his home in San Juan, Porto Rico. The local utility supplied a primary line at 2,200 volts and used converters to reduce the current to 110 volts for homes. On the day in question, the secondary current rose to dangerous voltage and passed into the house, killing him. Neighbors suffered similar shocks; converters were later found heated and a ground wire severed. The trial produced evidence about the utility’s inspections and the condition of its equipment.

Reasoning

The central question was whether the utility had failed to exercise reasonable care in maintaining its outside wires and converters. The Court said that when a person is injured by a dangerous instrumentality that was under a company’s exclusive control and the injury would not normally happen if proper care were used, the company must explain what caused it. Given the damaged converters, broken ground, and lack of a harmless explanation, the jury could reasonably find negligence, so the court’s instruction shifting the burden to the company was proper and the award was affirmed.

Real world impact

The ruling upholds the idea that utility companies can be held responsible when unexplained high-voltage surges from their equipment injure customers. It reinforces a duty to inspect and maintain transformers and grounding. Families harmed by similar unexplained equipment failures may be able to recover damages. The decision affirms that unexplained equipment failures found at the scene are strong evidence for juries to consider.