Helen J. Stoleson v. United States
1983 U.S. App. LEXIS 27489, 708 F.2d 1217 (1983)
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Rule of Law:
Under the 'eggshell skull' rule, a tortfeasor is liable for unforeseeable harm resulting from a plaintiff's preexisting vulnerability. However, the plaintiff bears the burden of proving with non-speculative evidence that the defendant's negligence was the actual cause of the subsequent harm, especially when the harm is psychological and other potential causes exist.
Facts:
- In 1967, Helen Stoleson began working at a federal munitions plant, where her job required her to handle nitroglycerin.
- She soon began experiencing severe chest pains, but only on weekends when she was away from the plant.
- In February 1968, she was hospitalized for what was diagnosed as a heart attack or coronary insufficiency.
- Stoleson continued to work and suffer from weekend chest pains until she left the plant in 1971.
- In 1971, Dr. Lange correctly diagnosed her heart condition as being caused by chronic exposure to nitroglycerin followed by withdrawal on weekends.
- Although the organic heart condition should have abated after she left the plant, Stoleson continued to suffer from debilitating symptoms including chest pains, dizziness, and fatigue.
- Medical experts for both parties later agreed that Stoleson's persistent symptoms had no organic basis and were the result of a 'hypochondriacal neurosis' (hypochondria).
- Experts disagreed on what triggered the hypochondria, with Stoleson's expert suggesting the 1968 heart episode, while also noting that advice from Dr. Lange and the stress of the lawsuit itself had aggravated her condition.
Procedural Posture:
- Helen Stoleson filed suit against the United States in 1974 under the Federal Tort Claims Act in a federal district court (court of first instance).
- At the first trial, the district judge dismissed the suit at the close of the plaintiff's evidence, ruling it was barred by the statute of limitations.
- Stoleson (appellant) appealed to the U.S. Court of Appeals for the Seventh Circuit, which reversed the dismissal and remanded the case for a new trial.
- The case was retried in the district court in 1981.
- Following the retrial, the district judge found the government was negligent and caused Stoleson's physical heart disease, awarding her $53,000 in damages.
- The district judge declined to award any damages for Stoleson's subsequent 'hypochondriacal neurosis,' finding she had failed to meet her burden of proof on causation for that condition.
- Stoleson (appellant) appealed the district court's denial of damages for her psychological condition to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Is a defendant who negligently caused a temporary physical injury liable for a plaintiff's subsequent and persistent hypochondriacal symptoms when the plaintiff has a preexisting psychological vulnerability and the evidence of causation is speculative?
Opinions:
Majority - Posner, Circuit Judge
No. A defendant is not liable for a plaintiff's psychosomatic symptoms, even under the 'eggshell skull' rule, where the plaintiff fails to meet her burden of proving a causal link between the defendant's negligence and those symptoms. The court acknowledged the validity of the 'eggshell skull' rule, which makes a tortfeasor liable for unforeseeable harm to a vulnerable plaintiff, including one with psychological vulnerabilities. However, the court interpreted the district court's decision not as a misapplication of this law, but as a factual finding that Stoleson had failed to prove causation. The expert testimony was deemed speculative and inconsistent, particularly regarding when the hypochondria began. The court was skeptical that the symptoms, which may have started years after the physical injury healed, were caused by the initial negligence rather than other stressors, such as her mother's death or the litigation itself. The court also noted that under a related principle, damages must be adjusted for the possibility that a preexisting condition would have caused harm even without the tort, a calculation Stoleson failed to provide.
Analysis:
This decision significantly qualifies the application of the 'eggshell skull' doctrine in cases involving psychological or psychosomatic injury. While affirming the rule that a tortfeasor takes the victim as they find them, the court establishes a high practical bar for proving causation. By advising 'healthy skepticism' towards claims of hypochondria and questioning whether litigation-induced stress is compensable, the opinion signals to lower courts to scrutinize such claims rigorously. This creates a greater burden for plaintiffs to present clear, non-speculative evidence directly linking the defendant's tortious act to the psychological harm, disentangled from other life stressors and the effects of the legal process itself.
