Shannon v. Wal-Mart Stores, Inc.
1998 Mo. App. LEXIS 1194, 974 S.W. 2d 588, 1998 WL 326718 (1998)
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Rule of Law:
A defendant whose negligence causes injury to a plaintiff is liable for subsequent aggravations of that injury, including aggravations caused by the plaintiff's development of a foreseeable, albeit unrelated, medical condition.
Facts:
- On September 17, 1995, Betty Shannon was shopping in a Wal-Mart store when boxes fell from an overhead display and struck her.
- Shannon suffered a disc herniation from the incident, which required surgery and resulted in ongoing pain, stiffness, numbness, and difficulty with her balance and gait.
- In April 1996, Shannon began experiencing new symptoms.
- In December 1996, Shannon was diagnosed with multiple sclerosis (MS).
- Both Shannon and Wal-Mart agreed that the incident at the store did not cause her to develop MS.
- The symptoms of Shannon's MS and the symptoms from her Wal-Mart injury aggravated one another; for example, inactivity during an MS attack could worsen the neck pain from the original injury.
Procedural Posture:
- Betty Shannon filed a lawsuit against Wal-Mart Stores, Inc. in a Missouri circuit court (the court of first instance) for personal injuries.
- Prior to trial, Wal-Mart admitted liability for the falling boxes.
- The case proceeded to a jury trial solely on the issue of the amount of damages Shannon was owed.
- The jury returned a verdict for Shannon, awarding her $337,500 in damages.
- Wal-Mart (as appellant) appealed the circuit court's judgment to the Missouri Court of Appeals, with Shannon as the appellee.
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Issue:
Does a plaintiff's development of an unrelated medical condition after an injury constitute a superseding intervening cause that relieves the original tortfeasor of liability for damages resulting from the interaction and mutual aggravation of both the original injury and the new condition?
Opinions:
Majority - Spinden, J.
No. A subsequently developed medical condition does not relieve the original tortfeasor of liability for aggravation damages if the development of such a condition was a foreseeable event. The law holds a negligent party responsible for all damages proximately traceable to the original negligence, including subsequent aggravation from an intervening cause that is a natural result of the injury. The court classified Shannon's development of multiple sclerosis as an intervening cause, but not a superseding one, because it was a foreseeable event. Foreseeability in this context does not require that the defendant predict the specific disease, but rather that the intervening cause be an ordinary human occurrence and not abnormal. Because the interplay between the original injury and the later-developed MS was a foreseeable consequence, Wal-Mart is liable for the damages arising from the mutual aggravation of the two conditions.
Analysis:
This decision clarifies and arguably extends the 'eggshell plaintiff' rule to encompass not just pre-existing conditions but also subsequently developed ones. It establishes that a defendant's liability can include the complex interplay between the injury caused and a later, unrelated disease, so long as the disease's development is considered a 'foreseeable event.' This prevents a defendant from severing the chain of proximate cause simply because a new medical issue arises post-injury. The ruling broadens the scope of recoverable damages for plaintiffs by holding tortfeasors accountable for the full, compounded consequences of their negligence as it affects the victim over time.
