Parrot v. Wells, Fargo & Co. (The Nitro-Glycerine Case) Case Brief Summary | Law Case Explained

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Parrot v. Wells, Fargo & Co. (The Nitro-Glycerine Case) | 82 U.S. 524 (1872)

Generally, an actor is liable for negligence if he breaches a duty to exercise reasonable care and causes harm. But is an actor liable for negligence if he isn’t aware of special circumstances that make his conduct risky? In Parrot versus Wells, Fargo, a package full of chemicals explodes in the hands of an express carrier, but the carrier didn’t have any reason to suspect that the package contained something hazardous.

Parrot owned a building in downtown San Francisco. He leased the basement and first floor to Wells, Fargo for its banking and shipping operations. Other tenants also occupied space in the building.

In New York, a shipper brought a package to a Wells, Fargo location. The package was destined for California, but the shipper said nothing about what was inside. It was a wooden box about two and a half feet wide. On the outside, the box was unremarkable. But on the inside of the box was nitroglycerine, an explosive liquid chemical.

Upon arrival in California, the box was leaking. Wells, Fargo employees followed the usual protocol for damaged shipments and took the box to their office space. An employee used a mallet and chisel to open the box, and the nitroglycerine exploded. The explosion killed everyone present and damaged the space Wells, Fargo leased and other spaces in the building.

Parrot filed suit against Wells, Fargo to recover for the building damage. Parrot claimed Wells, Fargo had a duty to investigate the contents of the box, which made it liable for the explosion.

The district court reasoned that Wells, Fargo employees had no reason to suspect the package contained something dangerous and that the employees weren’t negligent in handling the box. The court held that Wells, Fargo wasn’t liable. Parrot appealed to the Supreme Court.

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