Bartolone v. Jeckovich
N.Y. Sup. 1984 (1984)
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Rule of Law:
A defendant must take a plaintiff as they find them and is liable for all damages proximately caused by their negligence, including the aggravation of a pre-existing condition, even if the extent of the harm was unforeseeable.
Facts:
- On October 4, 1976, plaintiff was involved in a four-car collision for which defendants were responsible.
- Prior to the accident, the 48-year-old plaintiff was self-supporting, lived a placid existence, and suffered from a quiescent, pre-existing paranoid schizophrenic condition.
- The plaintiff had an intense emotional investment in his physical strength and physique, spending hours on body-building as a primary coping mechanism to maintain a sense of control.
- The accident caused relatively minor physical injuries, consisting of whiplash and cervical and lower back strain.
- After the accident, the plaintiff perceived his bodily integrity was permanently impaired, which deprived him of his coping mechanism.
- Subsequently, the plaintiff suffered an acute, total, and permanent psychotic breakdown, rendering him withdrawn, delusional, and unable to function.
Procedural Posture:
- The plaintiff sued the defendants in a trial court following a car collision.
- A jury found the defendants liable and returned a verdict of $500,000 in the plaintiff's favor.
- The defendants filed a motion to set aside the jury's verdict.
- The trial court granted the defendants' motion, ordering a new trial unless the plaintiff agreed to a reduced verdict of $30,000.
- The plaintiff refused to accept the reduced amount and appealed the trial court's order to the intermediate appellate court.
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Issue:
Is a defendant who is liable for a minor physical injury also liable for a plaintiff's subsequent, severe psychotic breakdown that resulted from the aggravation of a pre-existing but previously dormant schizophrenic condition?
Opinions:
Majority - Denman, J.
Yes. A defendant who is liable for a minor physical injury is also liable for a plaintiff's subsequent, severe psychotic breakdown that resulted from the aggravation of a pre-existing condition. The court applied the long-standing 'eggshell plaintiff' rule, which holds that a defendant must take a plaintiff as they find them and is therefore liable for the aggravation of a pre-existing illness. Although the plaintiff's physical injuries were minor, expert testimony established that his perception of bodily impairment directly triggered his latent schizophrenia, causing a total and permanent disability. The court cited precedents like Steinhauser v Hertz Corp. and McCahill v New York Transp. Co. to support the principle that a defendant is liable for the full extent of the harm, even if it is unforeseeably severe, and cannot argue that the plaintiff's condition might have occurred without the accident.
Analysis:
This decision strongly reaffirms the 'eggshell skull' plaintiff doctrine, particularly in its application to psychological injuries. It clarifies that a defendant's liability is not limited by the foreseeability of the extent or type of harm; if the defendant's negligent act proximately caused the injury, they are responsible for all resulting consequences. The case establishes that even a minor physical impact can serve as the legal cause of a catastrophic psychological breakdown if it aggravates a latent condition. This precedent makes it more difficult for defendants to mitigate damages by arguing that a plaintiff's unusual vulnerability, rather than their own negligence, is the 'true' cause of extensive harm.
