Summary of Hoyt v. Jeffers, 30 Mich. 181 (1874)

Facts: P’s hotel was burn down and P claimed that the cause of the fire was the sparks coming out of the chimney of D’s factory.  P did not present any direct evidence showing any particular spark starting the fire, but P did present abundant evidence showing how fires had previously been started by the sparks and how clothes left outside to dry had wholes in them due to the sparks from D’s factory.

Issue: Is this evidence admissible even though it did not provide any direct evidence?

Holding: Yes

Rationale:  “Now as the evidence of the burning of the plaintiff’s property complained of, need not and did not consist of direct evidence, that in that particular instance a particular spark was seen to come from the mill, traced by the same eye through the air and seen to light upon the side of the house and set it on fire, but the plaintiff must be at liberty to show, as he did, circumstances tending to prove that the property was set on fire in this way on the occasion alluded to, I can see no sound reason why he should not be at liberty to show any circumstances fairly tending to prove, or calculated to produce a reasonable belief, that this fire originated in this way on the occasion in question.”