Steinhauser v. Hertz Corp.
421 F.2d 1169 (1970)
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Rule of Law:
A defendant is liable for all resulting harm if their negligent act precipitates or triggers a plaintiff's latent, pre-existing physical or psychological condition into a manifest disability, even if the harm is unforeseeably severe.
Facts:
- Cynthia Steinhauser, a 14-year-old, had a history of some emotional sensitivity and had previously suffered a minor concussion from falling off a horse.
- On September 4, 1964, a car owned by Hertz Corporation and driven by Ponzini crossed a double yellow line and struck the car in which Steinhauser was a passenger.
- The occupants of the Steinhauser car, including Cynthia, suffered no immediate bodily injuries from the impact.
- Within minutes of the accident, Steinhauser began behaving in a highly agitated and unusual manner.
- In the days following, her condition deteriorated significantly; she developed delusions, became hostile, assaulted her parents, and attempted suicide.
- Steinhauser was subsequently hospitalized and received a diagnosis of an acute schizophrenic reaction.
- Expert medical testimony indicated that Steinhauser had a pre-existing predisposition to schizophrenia and the trauma of the accident was the 'precipitating cause' that activated this latent condition.
- Hertz Corporation's expert witness opined that Steinhauser was already schizophrenic at the time of the accident.
Procedural Posture:
- Cynthia Steinhauser's family (plaintiffs) filed a lawsuit against Hertz Corporation and Ponzini (defendants) in federal district court (a court of first instance).
- The case was tried before a jury.
- During deliberations, the jury submitted a question to the judge asking if they must find for the plaintiff if the accident was the 'precipitating factor' but not the 'cause' of the schizophrenia.
- The judge responded by rereading his initial jury instructions on proximate cause.
- The jury returned a verdict in favor of the defendants.
- The plaintiffs appealed the judgment to the United States Court of Appeals for the Second Circuit.
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Issue:
Is a defendant whose negligence acts as a precipitating factor for a plaintiff's latent psychological condition, causing it to manifest into a serious mental illness, liable for the full extent of the resulting harm?
Opinions:
Majority - Friendly, Circuit Judge
Yes. A defendant is liable for harm when their negligence acts as a precipitating cause for a latent condition. The 'eggshell skull' rule, which holds that a defendant must take their victim as they find them, applies to latent psychological conditions just as it does to physical ones. The trial court erred by forcing the plaintiffs into a false dilemma: either prove that the accident was the sole cause of schizophrenia in a 'perfectly normal' child or admit that she already had the active disease and the accident was irrelevant. This ignored the plaintiffs' valid legal theory, supported by their medical evidence, that the accident triggered a dormant predisposition. The jury's question about the distinction between a 'precipitating factor' and a 'cause' demonstrated their grasp of the true issue, but the judge's response, which merely repeated the flawed initial instruction, deprived the plaintiffs of a fair trial. Citing precedent such as McCahill v. New York Transportation Co., the court affirmed that liability exists where an injury precipitates an attack of a pre-existing condition.
Analysis:
This decision solidifies the application of the 'eggshell plaintiff' doctrine to cases involving latent psychological conditions. It establishes that 'precipitation' of a dormant illness is a valid theory of causation in tort law, distinct from either causing a new disease or aggravating a pre-existing active one. This precedent prevents defendants from escaping liability by arguing that a normal person would not have suffered such severe psychological trauma. It therefore broadens the scope of recovery for plaintiffs with underlying vulnerabilities, while also guiding courts on how to instruct juries in complex medical causation cases involving mental health.
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