Marion Collins v. N-Ren Corporation

Summary

The United States Court of Appeals for the Tenth Circuit held that Marion Collins presented sufficient evidence to proceed under Oklahoma's doctrine of res ipsa loquitur after an explosion at a fertilizer plant injured him. The court concluded that the trial court improperly denied the inference of negligence and reversed and remanded for a new trial.

Holdings

1. Collins established a prima facie case permitting him to proceed under res ipsa loquitur because the explosion was an event that ordinarily would not occur absent someone's negligence, the plant was within Cherokee's exclusive control, and Collins did not voluntarily act or contribute to his injuries.
2. Collins was not required to establish the precise origin of the fire to invoke res ipsa loquitur where he established that the fire caused the explosion, that the plant was under the defendant's exclusive control, and that direct proof of the cause and negligence was beyond his power.
3. N-Ren failed to submit rebuttal evidence sufficient to overcome the inference of negligence activated by Collins's prima facie showing.

Questions Presented

1. Whether Collins established the elements of a prima facie case under Oklahoma's doctrine of res ipsa loquitur.
2. Whether the inability to identify the precise origin of the fire prevented Collins from invoking res ipsa loquitur.
3. Whether the evidence was sufficient to permit an inference of negligence and require rebuttal by N-Ren.

Disposition

reversed_and_remanded