Thompson v. Lupone
62 A.2d 861, 135 Conn. 236, 1948 Conn. LEXIS 209 (1948)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A negligent defendant is liable for all damages proximately caused by their actions, even if the extent of those damages is unforeseeable due to the plaintiff's pre-existing physical or psychological vulnerabilities.
Facts:
- The plaintiff, a 31-year-old woman, was a customer at the defendants' restaurant.
- A waitress employed by the defendants negligently spilled a cup of very hot coffee on the plaintiff's left thigh and legs, causing first-degree burns.
- Reacting instinctively to the pain, the plaintiff jumped up and struck her right knee against an adjoining stool.
- The blow to her knee resulted in neuritis of the common peroneal nerve.
- At the time of the incident, the plaintiff had a pre-existing condition of being significantly overweight, weighing 261 pounds.
- Following the injury, the plaintiff developed post-traumatic anxiety regarding her future health.
- The combination of the injury, her obesity, and her anxiety prolonged her recovery period from an expected one or two weeks to six or eight months.
Procedural Posture:
- The plaintiff sued the defendant restaurant owners in a trial court to recover damages for personal injuries.
- The trial court, sitting without a jury, entered a judgment for the plaintiff, awarding her $2000 in damages.
- The defendants, as appellants, appealed the trial court's judgment to the present court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is a negligent defendant liable for the full extent of a plaintiff's injuries when those injuries are aggravated by the plaintiff's pre-existing physical conditions and post-traumatic mental suffering?
Opinions:
Majority - Dickenson, J.
Yes. A negligent defendant is liable for the full extent of a plaintiff's injuries, even if those injuries are aggravated by pre-existing conditions. The court reasoned that a tortfeasor must take their victim as they find them. The defendants' argument that the damages were excessive because the plaintiff's obesity and post-traumatic anxiety contributed to her suffering was rejected. The court held that mental suffering arising from a physical injury is compensable, and it was reasonable to find that the plaintiff's anxiety was a proximate result of the initial injury caused by the defendants' negligence. Therefore, the defendants were responsible for the entire, prolonged period of disability and suffering, not just the harm an average person might have sustained.
Analysis:
This case is a classic application of the 'eggshell plaintiff' or 'thin skull' rule, which holds that a tortfeasor is liable for the full consequences of their negligence, regardless of a plaintiff's unusual frailty. The decision affirms that this principle extends beyond just pre-existing physical conditions (like obesity) to include psychological conditions (like post-traumatic anxiety) that arise as a proximate result of the physical injury. This precedent solidifies that defendants cannot reduce their liability by arguing that the plaintiff was unusually susceptible to harm or that the resulting injuries were unforeseeably severe.
