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McCahill v. N.Y. Transp. Co. - 201 N.Y. 221, 94 N.E. 616 (1911)

Rule:

One who negligently forwards a diseased condition and thereby hastens and prematurely causes death, cannot escape responsibility even though the disease probably would have resulted in death at a later time without his actions. 

Facts:

While walking down the street, one of appellant's taxicabs struck respondent's intestate. As a result, intestate was thrown twenty feet and received a broken thigh and injured knee. He immediately became unconscious, was taken to a hospital, and died on the second day of delirium tremens. Respondent brought suit on behalf of intestate and the evidence permitted the jury to find that appellant was guilty of negligence and intestate free of contributory negligence. Appellant challenged the decision based on intestate's pre-existing alcoholic condition and on the question of whether appellant's negligence was the proximate cause of intestate's death.

Issue:

Can a driver be held liable for a pedestrian's death even if the pedestrian had a pre-existing alcoholic condition that might have contributed to his death?

Answer:

Yes

Conclusion:

The Court held that a negligent person is responsible for the direct effects of his acts, even if more serious, in cases of the sick and infirm as well as in those of healthy and robust people. In this case, the appellant's automobile struck and injured the traveler; the injuries precipitated, hastened and developed delirium tremens, and these caused death. There can be no doubt that the negligent act directly set in motion the sequence of events which caused death at the time it occurred. Moreover, the Court ruled that the cab driver was not made less certain because the facts of the case are somewhat unusual and the intestate had prior disorder of a discreditable character. 

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