Benn v. Thomas
512 N.W.2d 537 (1994)
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Rule of Law:
A defendant whose negligent act injures a plaintiff with a pre-existing physical condition is liable for the full extent of the harm, even if the harm is greater than what a person in normal health would have suffered. This is known as the "eggshell plaintiff" rule, which requires a defendant to take the plaintiff as they find them.
Facts:
- Loras J. Benn had a history of coronary disease and insulin-dependent diabetes, having previously suffered a heart attack in 1985.
- On February 15, 1989, Benn was a passenger in a van that was rear-ended by a semi-tractor driven by Leland R. Thomas on an icy road.
- As a result of the collision, Benn suffered a bruised chest and a fractured ankle.
- Six days after the accident, Benn died of a heart attack.
- An expert medical witness testified that the stress from the accident and the resulting injuries acted as 'the straw that broke the camel's back', triggering the fatal heart attack.
Procedural Posture:
- Carol A. Benn, as executor for the estate of Loras J. Benn, filed a lawsuit against Leland R. Thomas and his employers in an Iowa district court (trial court).
- At trial, the plaintiff requested a specific jury instruction on the 'eggshell plaintiff' rule, which the district court denied.
- The jury found the defendant's negligence caused Benn's immediate injuries but was not the proximate cause of his death.
- The district court denied the plaintiff's motion for a new trial based on the refused jury instruction.
- The plaintiff estate, as appellant, appealed the judgment to the Iowa Court of Appeals.
- The Court of Appeals reversed the district court's judgment, holding that the refusal to give the instruction was reversible error.
- The case was then appealed to the Iowa Supreme Court for review.
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Issue:
Does a trial court's refusal to give a specific jury instruction on the 'eggshell plaintiff' rule constitute reversible error when there is evidence that a defendant's negligence aggravated a plaintiff's pre-existing condition, even if a general proximate cause instruction is provided?
Opinions:
Majority - McGiverin, Chief Justice
Yes. A trial court's refusal to provide a specific 'eggshell plaintiff' instruction is reversible error when evidence supports its application. The general proximate cause instruction was insufficient because the 'eggshell plaintiff' rule is a distinct principle of tort liability that rejects the ordinary limit of foreseeability. The rule holds that once a defendant's negligence causes some injury, the defendant is liable for the full extent of the resulting harm, including the aggravation of a pre-existing condition, even if the severity of that harm was unforeseeable. Given the plaintiff's expert testimony linking the accident's stress to the decedent's heart attack, the estate was entitled to an instruction that clearly explained this principle to the jury.
Analysis:
This decision reinforces the 'eggshell plaintiff' rule as a fundamental component of tort law, clarifying that it is a rule of both proximate cause and damages. The court's holding emphasizes that a generic proximate cause instruction is legally insufficient in cases involving plaintiffs with pre-existing vulnerabilities. By requiring a specific instruction, the court ensures that juries are properly guided and not left to mistakenly apply a standard of foreseeability to the extent of the harm, thereby protecting the right of vulnerable plaintiffs to full recovery. This precedent strengthens the position of plaintiffs with latent conditions by requiring courts to explicitly address this doctrine in jury instructions when the evidence warrants it.
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