Benn v. Thomas
Citation: 512 N.W.2d 537 (Iowa 1994)
Facts
Benn was injured in a rear-end collision caused by Thomas’s negligence. Benn had a pre-existing heart condition. Although the accident was minor, it triggered a heart attack that killed Benn. Thomas argued that Benn’s extraordinary susceptibility to heart attack was an unforeseeable factor that broke the causal chain.
Issue
Is a defendant liable for the full extent of a plaintiff’s injuries, including those caused by a pre-existing medical condition, even if the full extent was unforeseeable?
Holding
Yes. Under the “eggshell skull” (thin-skull) rule, a defendant who causes injury to a plaintiff must take the plaintiff as he finds him. A defendant is liable for all consequences of a tortious act, even if those consequences are more severe than expected due to the plaintiff’s pre-existing vulnerability.
Rule
Eggshell plaintiff rule: Once a defendant is found to have caused a tortious injury, the defendant is liable for the full extent of the plaintiff’s harm — including injury that resulted from the plaintiff’s pre-existing susceptibility — even if the full extent was not foreseeable. “You take your plaintiff as you find him.”
Significance
- Classic application of the eggshell plaintiff (thin skull) rule
- Limits the foreseeability test (Wagon Mound): foreseeability governs the type of harm (the accident must be foreseeable), but the extent of harm need not be foreseeable once a foreseeable type of harm occurs
- Applies to pre-existing physical conditions (brittle bones, heart conditions), but may not extend to purely psychological vulnerability in all jurisdictions
- Paired with Derdiarian and Wagon Mound I in proximate cause discussions