Question: An interesting variation on the facts in Ploof occurred in Vincent v. Lake Erie Transport Co., 109 Minn. 456, 124 N.W. 221 (Supreme Court of Minnesota, 1910). In late November, 1905, the steamship Reynolds, owned by the defendant, was moored to the plaintiff's pier in Duluth and discharging cargo. A storm suddenly arose on Lake Superior. The Reynolds signaled for a tug to take her away from the pier, but because of the storm, none could be found.
The ship remained moored to the pier during the storm. The violence of the storm threw the steamship repeatedly against the plaintiff's pier, causing damage in the amount of $300. The plaintiff asked for that amount. The Lake Erie Transport Co. contended that its steamship was an involuntary trespasser. The Reynolds had tried to leave the plaintiff's property but had not been able to do so through no fault of its own. The court held that the plaintiff was entitled to damages. Argue that this holding is efficient.