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Benn v. Thomas

(1994)

Iowa Supreme Court - 512 N.W.2d 537

tl;dr:

Defendant negligently caused a car accident, resulting in death of someone with a history of coronary disease; Court holds that decedent's unforeseeable weaker condition did not defeat proximate cause (eggshell plaintiff rule).

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Facts & HoldingBenn v. Thomas case brief facts & holding

Facts:Defendant's vehicle rear-ended the van in which Plaintiff Benn was...

Holding:The Iowa Supreme Court affirmed, holding that the eggshell plaintiff...

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Majority opinion, author: McGIVERIN, Chief Justice.
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The case involves a motor vehicle accident caused by the defendant's negligence, resulting in the plaintiff's decedent suffering injuries. The decedent died six days later due to a heart attack caused by a pre-existing condition. The plaintiff's estate filed a lawsuit seeking damages for the injuries and death. The trial court erred in refusing to instruct the jury on the "eggshell plaintiff" rule, which holds that a tortfeasor may be liable for the full extent of a plaintiff's injuries even if the plaintiff had a pre-existing condition that made them more susceptible to injury. The court of appeals found this to be reversible error and remanded the case for a new trial. The rule is a rule of proximate cause as well as damages and has been incorporated into the damages section of the Iowa Uniform Civil Jury Instructions. If the jury instructions contain a material misstatement of the law, the trial court cannot deny a motion for a new trial.

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