Benn v. Thomas

Supreme Court of Iowa · 1994 · Torts

Tortseggshell plaintiffproximate causejury instructionseggshell plaintiffthin skull ruleproximate causeforeseeability

Facts

Loras Benn was injured when defendant's semi-tractor and trailer rear-ended the van in which he was riding on an icy road. He suffered a bruised chest and fractured ankle, and six days later died of a heart attack. Loras had a history of coronary disease, diabetes, and a prior heart attack, and the estate's medical expert testified that the accident and its attendant bodily stresses were the cause of his death. The trial court refused the estate's requested eggshell-plaintiff instruction and gave only a general proximate-cause instruction, after which the jury awarded damages for injuries but none for death.

Issue

When there is evidence that a defendant's negligent act caused some injury and may have aggravated the plaintiff's preexisting heart condition, must the jury be specifically instructed on the eggshell plaintiff rule? Put differently, did the general proximate-cause instruction adequately convey the applicable law without that specific instruction?

Rule

If a defendant's negligent act causes some injury to a plaintiff, the defendant takes the plaintiff as found and is liable for the full extent of the resulting injuries even when a prior latent or infirm condition makes the harm greater than what a normal person would have suffered. In such a case, where the evidence supports application of the rule, a general proximate-cause instruction alone is insufficient because the eggshell plaintiff rule is also a rule of proximate cause that rejects the ordinary foreseeability limitation for the extent of personal injury.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Des Moines, Caleb Orr negligently sideswiped Nina Patel's car at low speed. Nina suffered a bruised shoulder, and three days later she experienced a retinal detachment; her ophthalmologist testified that the collision trauma triggered it because Nina had an unknown degenerative eye condition that made her unusually susceptible, while the defense expert said the detachment was unrelated.

If the jury will be asked whether Caleb's negligence proximately caused Nina's retinal detachment, which instruction is most necessary if requested?

Explanation. The majority treated the eggshell plaintiff rule as equally a rule of proximate cause, not merely damages. When there is evidence the defendant caused some injury and the plaintiff's latent condition may have made the resulting harm worse, the jury must be specifically told that foreseeability does not limit liability for the full extent of personal injury. A general proximate-cause instruction alone is inadequate on those facts, and conflicting medical evidence does not bar the instruction if the jury could reasonably find causation.