Using economic principles, analyse the law of obligation (Negligence) - Essay Example

?Using Economic Principles, Analyse the Law of Obligation (Negligence) Economic analysis of law uses microeconomic hypotheses to examine rules of negligence and obligation. Economic analysis of law brought at the centre of academic discourse by Richard Posner in 1973 in The Economic Analysis of Law. His work paved the way for precise legal debates on the economic analysis of the law and laid strong foundations for subsequent literature on the economic analysis of the law of negligence. There have been several writers on the economic analysis of the law, some with same viewpoints and same with variations on how law should be affected by economics1. For example, Friedman calls for an economic analysis of law for the simple reason that there should be some strong connection liking effectiveness and justice. He believes that effectiveness stands at the centre of what economics provide today and for this reason, it is better if economic ideas can shape the law. Friedman further asserts that economics is a deep-seated issue is the connotation of reasonable choice, and therefore, an indispensable tool for sculpting the outcomes of legal rules.2 Wolfgang on his part states that economic analysis of the law means that there should always be awareness on the issue of why, along with how human interactions can be guided effectively by the law. He believes economic tools can be used to guide human actions, with particular attention to obligations owed towards others3. One yet school of thought is that posited by Mitchell and Shavell who believe that there should and for all times, be a good probability for the imposition of sanctions on negligent behaviour. Economic analysis will therefore guide the magnitude and form of these sanctions so that eventual liability would cause deterrence on the part of the torfeasor.4 Much debate about economic analysis of law has been also been propounded by Ronald Coase (1961)5, Guido Calabresi (1961)6, Commons [1924]7, Hale [1952]8 as well as Richard Posner [1973]9 with controversial ideas in his assertion that rules of common law are efficient and that rules of law must be efficient. He explains “efficient” to mean compliance to pay. In trying to have comprehensive understanding of these, Kornhauser (1984, 1985)10 brings two assertions: efficient rules are selected for legal processes and people are motivated to fear the law because of its economic consequences. These assertions however, do not match up unswervingly to conventional questions in the philosophy of law because normativity and the requirement to comply with the law are not openly looked at. Economic analysis of law will use a policy perspective to make this evaluation and this angle of reasoning often absolutely adopt some alternative of legal positivism. Analyzing the behavioral effects of the law, it is posited that the law is clearly known only by judges rather than the subjects of the law. Of course, there is strong reason for wanting to believe that the present American tort law supports the basis for the economic analysis of the law. This particularly relates to the section of economically analyzing the law often called wealth maximization stating that there must be equality of positions between the plaintiff and defendant. This is very true if the plaintiff is thinking of productively benefiting from the negligence of breach of obligations on the part of the defendant. Amartya says: “The need for incentives may be rightly seen as including an element of blackmail. It would typically include the claims to higher reward for the better endowed and the more productive, who can decide to do less of those of their activities that benefit others, unless they receive more ‘compensation’. If this connection does actually work this way, then an uncompromising pursuit of equality may be self-defeating. Blackmail or not, the incentive connections must be taken into account by someone trying to promote equality”.11 In the late 19th century, economic analysis of the law was experienced. This paved that way for what became known as western jurisprudence. Most of these were based on Guido Calabresi's Property Rules, Liability Rules, and Inalienability.12 In relation to the studies of Lewis13 in the preceding century, Coase as well as Calabresi laid their emphasis on issues relating to formation, evaluation, and obliteration of economically important rights in property.14 The period was followed by the ideas of Becker and Posner. In fact, the birth of the first modern revolution of economic analysis of the law was the University of Chicago, where Henry Simons15 as well as Aaron Director16 advocated a revolution to have economic considerations implanted at the center of decisions making. Gary Becker17 with Richard Posner18 had guidance from Aaron Director and they examined and construed the studies of Coase19 and Calabresi' in addition to other works20. When Calabresi’s ideas were being followed by those of Posner, H. Scott Gordon was already writing on the problem of limited resources21, and this expanded into the principal debates for environmental stewardship law. Later, there was a shift from expressive to normative standard. Conventional economic analysis of law was simply based on the hypothetical aspect of the analysis, primarily focused on exploring and developing the descriptive aspects of the theory. Therefore, law and economic analysts were chiefly concerned with the is proposition, rather than the ought proposition of law. Keep in mind that they had one thing in mind. To make use of economics and its logic to explain how law is made. They also sought explaining why people are compelled to act in accordance with the law. Therefore, judges made use of an economic analysis of law to arrive at their decisions, what's more, by diminishing the price of getting into negotiations, or by replicating what would have normally been the result, if the prospect for freely entering into negotiations had been open to the concerned litigants. This development was reflected in movements such as “ behavioral law and economics ”, “ socio-economics ” or “ law and society ”, leading judges in tort cases to come up with words or phases such as “ due ” or “ reasonable care ”, “ common ” or “ ordinary use ”, “ negligence ”, etc. could be considered as an implicit allusion to the idea of efficiency22. This led to Judge Hand’s decision in U.S. v. Caroll Towing Co23 culminating to the famous “Hand Formula” where liability for negligence will be imposed on the defendant if it is established that the loss resulting from the negligent act, when multiplied by the likelihood of the accident’s occurrence, is more than the cost of preventive measures that the defendant ought to have taken to steer clear of inflicting the loss. At least, this shows the law to be effective. Therefore, the “ objective ” variables of probability of the likelihood of a negligent act, the economic valuation of the loss and the amount of precaution needed to avoid the loss is used, instead of a casual connection connecting the defendant and the plaintiff, removing the issue of causation. If this reasoning is considered best, then how should economic analysis of law make the decision-making process effective? It is thought that not all, but most of common law has been made effective. An example of such thought is that of Posner who states that “the common law’s commitment to efficiency is strong, but not total”24. While the common law system in general tends to promote economic efficiency, some anomalies could subsist. Economic analysis of the law can best be illustrated by examining the elements of negligence through the Caparo Test. Caparo Industries plc v Dickman25 is one of the foremost legal authorities for duty of care or observing obligations on others. The House of Lords established the "Caparo Test “or the "three-fold test" stating that for a duty of care to be owed: There ought to be a "reasonably foreseeable" harm from defendant’s conduct; "Proximity" must link the defendant and the plaintiff; Imposition of liability must be "fair, just and reasonable". In formulating this test, Bingham LJ stated that: "It is not easy, or perhaps possible, to find a single proposition encapsulating a comprehensive rule to determine when persons are brought into a relationship which creates a duty of care upon those who make statements towards those who may act upon them and when persons are not brought into such a relationship."26 This difficulty has been reiterated by the courts in other cases. In Hedley Byrne & Co Ltd v Heller & Partners Ltd27 Lord Hodson said: "I do not think it is possible to catalogue the special features which must be found to exist before the duty of care will arise in a given case," and Lord Devlin said: "I do not think it possible to formulate with exactitude all the conditions under which the law will in a specific case imply a voluntary undertaking any more than it is possible to formulate those in which the law will imply a contract."28 In Mutual Life and Citizens' Assurance Co Ltd v Evatt29 Lord Reid and Lord Morris of Borth-y-Gest said: "In our judgment it is not possible to lay down hard-and-fast rules as to when a duty of care arises in this or in any other class of case where negligence is alleged." In Rowling v Takaro Properties Ltd30, Lord Keith of Kinkel emphasised the need for careful analysis, case by case: "It is at this stage that it is necessary, before concluding that a duty of care should be imposed, to consider all the relevant circumstances. One of the considerations underlying certain recent decisions of the House of Lords31 and of the Privy Council32 is the fear that a too literal application of the well-known observation of Lord Wilberforce in Anns v Merton London Borough Council33, may be productive of a failure to have regard to, and to analyse and weigh, all the relevant considerations in considering whether it is appropriate that a duty of care should be imposed. Their Lordships consider that question to be of an intensely pragmatic character, well suited for gradual development but requiring most careful analysis. It is one upon which all common law jurisdictions can learn much from each other; because, apart from exceptional cases, no sensible distinction can be drawn in this respect between the various countries and the social conditions existing in them. It is incumbent upon the courts in different jurisdictions to be sensitive to each other's reactions; but what they are all searching for in others, and each of them striving to achieve, is a careful analysis and weighing of the relevant competing considerations." Coparo Conditions 1. Reasonable Foreseeability If the likelihood of an injury is high or low, it ought not to have an effect on its inclusion or exclusion from the possibility of responsibility. Shavell (1980)34 puts it in plain words that even if the likelihood of the injury is minimal, the negligent act which constitutes the reason of an increase in likelihood should bear responsibility. Accordingly, standard claims should be that on every occasion that an act is an essential cause of the injury, liability ought to follow. Yet, to establish the enticement effects that any extent of legal responsibility generates, we cannot rely on the objective probability of injury, but the subjective probability. Calabresi (1975)35 opines that there is no reason to punish an act which is an indispensable reason for harm, by menacing to compel legal responsibility on a defendant who dispenses a subjective possibility of zero to the plaintiff. This means that if the defendant does not reasonably foresee the injury, he should not be held liable. Shavell (1980)36 makes this clear that, each time subjective probability is minimal in absolute terms as well as lesser than objective probability in relative terms, legal responsibility ought not to create adequate ex ante behavioral effects to give good reason for adding in the expenses of dispute resolutions. It may happen that the defendant does not reasonably foresee the consequences of his acts. But, the defendant possibly will still be in a situation to relate an act with unexpected risks. The defendant may be aware of a large variation of results even though he fails to take note of the nature of every result. Therefore, apportioning responsibility for unforeseen harms can desirably lead to the reduction or minimization of the extent of action that is established, ex ante, to bring together various unforeseen risks. Two well-known tort doctrines can add extra explanation to role economics in analyzing foreseeability in negligence. The first doctrine makes a distinction between classes of injuries, as explained by Palsgraff v. Long Island37. The second doctrine relates to the “egg shell” or ”thin skull” principle whereby liability will be imposed by the law on the defendant for injury, amounting to the entire severity of the harm, even if the degree of the harm was unforeseeable because of the existence of a condition on the part of the plaintiff. Shavell (1980)38 states that this cancels out the basic economic insight, stating that as soon as the likelihood of high loss is methodically taken too lightly, placing liability of the defendant for the entire injury does not perk up the chances of increasing the incentive to be precautionary. Therefore, if victims with low harm are given the full object to receive damages, it is reasonable that plaintiffs with abnormal phlegm should be given the same consideration. This is necessary to establish the acceptable measure of average responsibility ex ante. Reasonable foreseeability is not needed in all cases ahead of imposing a duty of care39. Lord Keith of Kinkel reiterated this in Hill v Chief Constable of West Yorkshire40. Foreseeability cannot be discussed without laying enpahasis on causation. At first, in the economic theory, the law of tort intentionally rejected an open position for the use of causation to establish liability for negligence. Coase’s (1960)41 was very firm for such rejection. He explained injury to be the outcome of common result of mutual and symmetric contact between people. For influential or policy considerations, Calabresi (1970)42 believes that the party with the least precautionary measure should bear the liability. Causation therefore becomes a conclusion if it is not construed as an opening condition for the establishment of liability in negligence43. This way of reasoning has been corroborated by Landes and Posner44. They assert that ‘the idea of causation can largely be dispensed with in an economic analysis of torts’. If the aim of the law of tort is to advance economic efficiency, then the party who took the least measure to prevent injury should be liable for negligence. This position was well established and understood, following Brown’s (1973)45 formulation of an accurate model of accidents. This later turned out to be a point of reference for succeeding economic analysis law of negligence, allocating identical roles to the defendant and the plaintiff, by making the expected harm a focal point of the measure of care that should be taken by all parties. As a consequence, economic analysis of the law of negligence reduces the requirement of cause to efficient avoidance. The obligation of cause is reliant exclusively upon the opinion on the economic efficiency of preventive measures. This has been referred to as causal minimalism and a good number of authors have argued that causation puts goals in place of efficiency46 or that it merely represents an older method of conducting efficiency analysis47. 2. Proximity The requirement of proximity is harder to pin down. According to Lord Atkins, it is not plain physical proximity but pulls out to “such close and direct relations that the act complained of directly affects a person whom the person alleged to be bound to take care would know would be directly affected by his careless act:"48. In most cases, the unusual term "neighbourhood" is employed as was by Lord Reid in the Hedley Byrne case49 and Lord Wilberforce in Anns v Merton London Borough Council50. If we have to relate this to the law of obligations, we will realize that proximity must be "equivalent to contract"51, or "only just short of a direct contractual relationship" as per Lord Fraser of Tullybelton in Junior Books Ltd v Veitchi Co Ltd52, or is "as close as it could be short of actual privity of contract:"53 3. Imposition Of Liability Must Be "Fair, Just And Reasonable" Perhaps, this covers the same obligations like the second stage test of Lord Wilberforce's in Anns v Merton London Borough Council54, in addition to what has been known as policy in legal decisions such as in Spartan Steel & Alloys Ltd v Martin & Co. (Contractors) Ltd55 as well as McLoughlin v O'Brian56. Concerns of such nature led Lord Fraser of Tullybelton to think that "some limit or control mechanism has to be imposed upon the liability of a wrongdoer towards those who have suffered economic damage in consequence of his negligence as was the position in Candlewood Navigation Corporation Ltd v Mitsui OSK Lines Ltd57. Conceivably, the best was to represent this obligation is by borrowing the words of Weintraub C.J. in Goldberg v Housing Authority of the City of Newark58: "Whether a duty exists is ultimately a question of fairness. The inquiry involves a weighing of the relationship of the parties, the nature of the risk, and the public interest in the proposed solution." If imposing a duty on the defendant ought to be unfair, or would render the defendant "to a liability in an indeterminate amount for an indeterminate time to an indeterminate class,"59 this is going to weigh a great deal, and perhaps decisively, be in opposition to imposing a duty. But a duty will be imposed if the defendant is willingly carrying out some form of professional ability for payment and if the plaintiff has no other means of redress,60 or if imposing a duty is calculated to encourage some collectively wanted purpose. Today, there is visible overlap between the conditions of the Caparo Test and as Lord Hoffmann puts it in Sutradhar v NERC61, the limits between these conditions are “somewhat porous but they are probably none the worse for that”. This however leads to evidence that there are shortcomings within the “foreseeability’” feature of the Caparo Test, compelling the courts to go beyond the “neighbour” principle of Lord Atkin in Donoghue v Stevenson62 stated as follows: “The rule that you are to love your neighbour becomes in law, you must not injure your neighbour; and the lawyer’s question ‘Who is my neighbour?’ receives a restricted reply. You must take reasonable care to avoid acts or omissions which you can reasonably foresee would be likely to injure your neighbour. Who, then, in law is my neighbour? The answer seems to be – persons who are so closely and directly affected by my act that I ought reasonably to have them in contemplation as being so affected when I am directing my mind to the acts or omissions which are called in question.” As far as foreseeability is concerned, Donoghue v Stevenson unquestionably rests as binding precedence of the law with regards to duty of care. But foreseeability is just a single element, prompting Lord Reid to comment that: “In later years, there has been a steady trend towards regarding the law of negligence as depending on principle so that, when a new point emerges, one should ask not whether it is covered by authority but whether recognised principles apply to it. Donoghue v Stevenson may be regarded as a milestone, and the well known passage in Lord Atkin’s speech should, I think, be regarded as a statement of principle. It is not to be treated as if it were a statutory definition. It will require qualification in new circumstances. But I think the time has come when we can and should say that it ought to apply unless there is some justification or valid explanation for its exclusion.”63 Brennan J, an eminent Australian Judge, has tackled the inadequacy of foreseeability to be used as a distinct assessment in that: “Lord Atkin’s ‘neighbour’ test involves us in hopeless circularity if my duty depends on foreseeability of injury being caused to my neighbour by my omission and a person becomes my neighbour only if I am under a duty to act to prevent that injury to him. Foreseeability of an injury that another is likely to suffer is insufficient to place me under a duty to act to prevent that injury. Some broader foundation than mere foreseeability must appear before a common law duty to act arises.”64 For this reason, foreseeability alone will erroneously be used for imposing liability.65 It therefore becomes apparent to refer to what Lord Goff said in AG of the BVIs v Hartwell: “I wish to emphasise that I do not think that the problem in these cases can be solved simply through the mechanism of foreseeability. When a duty is cast upon a person to take precautions against the wrongdoing of third parties, the ordinary standard of foreseeability applies…..there is at present no duty at common law to prevent persons from harming others by their deliberate wrongdoing, however foreseeable such harm may be if the defender does not take steps to prevent it”66. There is equally an overlap between proximity and policy67, so much so that the two elements can “conveniently be considered together”68. With regards to the notion of fairness if we have to establish negligence using the Hand Formula in the law of tort, Shavell plainly states that: “As in the unilateral model, if the courts choose due care to equal the socially optimal level, then injurers will be led to take due care. Victims too will be induced to take the optimal level of care because they will bear their losses if injurers take due care. (Drivers will be led to take due care; and knowing that they will bear their losses, bicyclists will decide to take appropriate care.)”69 There should be some confines of prescribed economic analysis of the law. Law and economics movement is considered to have started from the law of tort. “The law of accidents was one of the first bodies of private law successfully analyzed using formal economic models,”70 It is generally argued that the law of tort ought to be regulated through some prescribed economic analysis71. Understanding the law from an economic point of view such as using the Hand Formula will help us have an inclusive explanation of “reasonable precautions” like those that should be cost-justified72. Physical harm and economic loss Through the years, a division has been made, dividing what the law prescribed between the reality of a duty to stop physical harm and a duty not to render a plaintiff to unfavourable economic costs. However the law of negligence has evolved only to provide coverage for pure economic loss, thereby, permitting the courts to enter into more deliberations to think of the limits and conditions required for imposition of liability. This development actually started in Hedley Byrne v Heller73 and it is today more established in Caparo Industries v Dickman. Arguments have however been stated that the Caparo Case is on economic loss and contains all the requirements for the establishment of liability. Lord Hope expressly made it clear that74 “…the origins of the fair, just and reasonable test show that its utility is not confined to that category” conditions for the imposition of liability and eventual duty of care was explained by Lord Bridge when he said: “What emerges is that, in addition to the foreseeability of damage, necessary ingredients in any situation giving rise to a duty of care are that there should exist between the party owing the duty and the party to whom it is owed a relationship characterised by the law as one of ‘proximity’ or ‘neighbourhood’ and that the situation should be one in which the court considers it fair, just and reasonable that the law should impose a duty of a given scope on the one party for the benefit of the other.”75 Conclusion Economic analysis of the law has invaded the development of case law insidiously. Proponents of the economic analysis of the law have not faced the proper challenge between relationships of economic and legal analysis. If we have to hold this view as true, it may mean that we should also have a shift in the normal way in which the courts decide cases, into using economic principles. Economic analysis of the law has not change this methodology greatly. We must realize that economics is all about studying the market and every legal system is akin to a market in which the law of obligations creates commitments that people must follow if they are to uphold their duty of care to others. While economic analysis of the law perks up out reasoning on the manner in which these obligations operate, they do not help very much in the legal decision-making process. There may therefore never be an era in which judges will be substituted by economists. Posner has commented that "it would not be surprising to find that many legal doctrines rest on inarticulate gropings toward efficiency”76. The essence is that judges and economists tend to reason to arrive at similar outcomes, but they do this by traveling different routes. It is evident that an economic analysis of the law provides some useful insight into the potency of the law to ensure that precautionary measures ensue in the society as well as to diminish the effects of negligent acts. But there are also criticisms to this with regards to substantive norms along with its structural features. Firstly, economists hold that analyzing the law of obligations the way they do is to make sure that people act responsibly. This is the more reason why reasonable risk-taking is explained and distinguished from rational risk taking. On the other hand, economic analysis of the law is unsuccessful in making good analysis of the notion of legal duty in a usual manner. If the law obliges us not to injure; what does the law want from us and to whom should we reflect these obligations? There is therefore a distinction between scope and extent and emphasis on this has been stressed by Judge Cardozo in Palsgraf v. Long Island Rail Road: “I have a duty to guard against injuring those who fall within the ambit of foreseeable risk associated with my conduct. Others might be injured by what I do, and what I do might be lamentable or mischievous, but those who fall outside the ambit of foreseeable risk have no claim against me in tort. This is not because I do not act badly or carelessly toward them. Ex hypothesi, I do. Nor is it because my careless behavior does not injure them. Ex hypothesi, it does. They have no claim against me because I have no legal duty to take their interests into account”77. Secondly, economic analysis of the law stressed much on affiliation between the defendant and the plaintiff. For this reason, there ought not to be any essential reason on which a plaintiff should sue the defendant. There is equally no reason why a plaintiff must dispute the fact that he was injured by the defendant, rather than that there was a preventive measure on the part of the defendant to minimize cost. Perhaps, the best way to look at economic analysis of the law is to look at it from a reformative angle through the following questions: What substantive responsibility rules will impute the utmost impact on minimizing the occurrence of injury at the least cost? What rules of procedure will persuade those at trials to disclose information? What substantive as well as procedural rules can culminate to best possible investments in safety? Economic analysis of the law will therefore be more persuasive if looked at from the point of view of a reformist, rather that of an economist, judge or litigant. 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