Ranson v. Kitner

Appellate Court of IL - 1889

Facts:

• D shot P's dog while hunting for wolves because P's dog looked much like a wolf.

• Trial court found for P. D appealed citing a good faith mistake as his defense.

Procedural History:

• Trial court found for P, awarded $50 as the value of the dog.
• IL Appellate Court affirmed, found for P.  

Issues:

• Is good faith mistake a defense to intentional torts where the D intended the consequence of his act?

Holding/Rule:

• Good faith mistake is not a defense to intentional torts where the D intended the consequence of his act.

Reasoning:

• D intended to shoot (intended to bring about a harmful or offensive touching).
• The necessary intent is not to kill a dog but to shoot an animal.
• It does not matter that D was incorrect about who the receiver of his act was; he is liable.

Dissent:

• None.

Notes:

• Trespass to chattels case -- substantial interference on the property of another.
• Good faith mistake does not negate intent.
• Public policy of promoting socially responsible behavior -- look before you shoot.