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Historically much of the law of tort was concerned with Trespass of one form or another. A trespass was, and is, an interference with the rights of another person, either in person, land, or chattels. Trespass could generally only be found where the harm resulted from the direct action of the defendant - a blow, for example. There remained a residual ability to sue 'in case' or bring an 'action on the case' where the interference was not direct. For example, if the defendant throw a log onto the highway, and it hit the claimant, this would have been a trespass. If the claimant injured himself by tripping over it, this would have allowed only an action 'on the case'. If the defendant threw the log with the intent to injure the claimant, then there was also the possibility of an action under the rule in Wilkinson v downton (1897).

These days, 'actions of the case' have been subsumed into the general law of Negligence, and the distinction between tresspass and negligence now rests on the motive of the defendant, not the directness of the action (see: Letang v cooper (1964)).