Work through an eggshell-plaintiff proximate-cause question with examiner-style analysis on unforeseeable severity, preexisting conditions, and full-damages liability.
Derrick glanced down at his phone for two seconds while driving through downtown traffic and lightly rear-ended Paula at a stoplight. The impact dented Paula's bumper but looked minor. Paula, however, had an unknown brittle-bone disorder that made her unusually susceptible to fracture. The collision caused multiple spinal fractures, a lengthy hospitalization, and permanent mobility limits. Derrick argues that even if he was negligent, he should be liable only for the sort of soft-tissue injuries an ordinary driver would foresee from a low-speed collision, not for Paula's catastrophic injuries caused by her hidden condition. Paula sues Derrick for negligence.
Yes. Derrick is liable for Paula's full injuries because the eggshell-plaintiff rule makes a negligent defendant responsible for unforeseeably severe harm caused by the plaintiff's preexisting vulnerability. A negligent defendant takes the plaintiff as the defendant finds the plaintiff. Under the eggshell-plaintiff rule, once some bodily injury to the plaintiff is a foreseeable result of the defendant's negligence, the defendant is liable for the full extent of the actual injury even if the severity is magnified by a preexisting weakness, illness, or unusual susceptibility. Proximate cause focuses on whether the general type of harm was foreseeable, not whether the precise extent of damages or the plaintiff's vulnerability was foreseeable. The rule therefore distinguishes unforeseeable extent from unforeseeable type: an unexpectedly severe physical injury does not cut off liability when physical impact was itself a foreseeable consequence of the negligent act.
Is Derrick liable for the full extent of Paula's severe injuries even though her extraordinary susceptibility made the harm far worse than a reasonable driver would have expected?
A negligent defendant takes the plaintiff as the defendant finds the plaintiff. Under the eggshell-plaintiff rule, once some bodily injury to the plaintiff is a foreseeable result of the defendant's negligence, the defendant is liable for the full extent of the actual injury even if the severity is magnified by a preexisting weakness, illness, or unusual susceptibility. Proximate cause focuses on whether the general type of harm was foreseeable, not whether the precise extent of damages or the plaintiff's vulnerability was foreseeable. The rule therefore distinguishes unforeseeable extent from unforeseeable type: an unexpectedly severe physical injury does not cut off liability when physical impact was itself a foreseeable consequence of the negligent act.
Derrick's negligence created the foreseeable risk of a car accident causing bodily injury to the driver he hit. That is enough to establish the relevant type of harm. Paula's fractures were dramatically worse than what most people would have suffered in the same low-speed collision, but the eggshell-plaintiff rule says Derrick bears that risk once he negligently caused a physical impact. He cannot reduce damages by arguing that Paula happened to be unusually fragile. The defendant need not foresee the plaintiff's exact medical condition, exact fracture pattern, or exact long-term prognosis. Those facts go to extent of injury, not to the basic foreseeability of personal injury from a rear-end collision. Derrick might try to characterize Paula's condition as a superseding cause, but a preexisting condition is not an independent intervening force; it is part of the plaintiff as found. He also may argue that the damage award should be limited to what an ordinary person would have suffered, yet that is precisely what the eggshell rule rejects. Because some physical injury was a natural and foreseeable result of negligent driving, Derrick is liable for the full consequences actually inflicted on Paula.
Yes. Derrick is liable for Paula's full injuries because the eggshell-plaintiff rule makes a negligent defendant responsible for unforeseeably severe harm caused by the plaintiff's preexisting vulnerability.
That is the exact limitation the eggshell-plaintiff rule rejects. The defendant pays for the plaintiff actually injured, not a hypothetical average plaintiff.
The defendant need not foresee the plaintiff's hidden susceptibility. Foreseeability concerns the general type of harm, not the plaintiff's exact medical vulnerability.
A preexisting physical condition is not an independent intervening force. It is part of the plaintiff as found.
It is a standard negligence damages principle and frequently tested in ordinary auto-accident fact patterns.