I found the case Byrne v. Boadle, where a plaintiff was struck by a barrel falling from above, from shop out on a street. Plaintiff sued Boadle, the shopkeeper, on grounds that he was negligent in securing the barrel. Boadle argued that there was no evidence to demonstrate his carelessness or negligence. The question before the court was whether negligence could be inferred when no evidence existed. The court ruled that yes, when the fact pattern was such that negligence was highly probable, negligence could be inferred without additional evidence. The case is from 1863 Liverpool, England. Presumptive negligence, as the doctrine is referred to today, is still very much around. It has also given rise to the doctrine of res ipsa loquitur, or latin for "the thing speaks for itself." In a 2021 Case Borden v. U.S. the Supreme Court elaborated on the usage of the doctrine. There the Court was explaining why it used one interpretation of a phrase over another and cited it "obvious" or "inferred" definition from another case. The concept has evolved since Boadle, that some definitions or fact patterns are so obvious, that they "speak for themselves" and do not need additional proof or evidence. In another case, Bank of America v. 203 N. Lasalle, the Court used the doctrine to opine on equity transfers when creditors have not yet been paid in full. To the Court it was obvious that such a transfer could not happen until everything had been paid up, it was obvious - res ipsa loquitur