Law School Case Brief
Stoleson v. United States - 708 F.2d 1217 (7th Cir. 1983)
The "thin skull" or "eggshell skull doctrine" means the defendant takes their victim as he or she finds them.
Helen Stoleson, a worker in a federal munitions plant, suffered a heart attack and filed suit under the Federal Tort Claims Act, 28 U.S.C.S. §§ 1346(b), 2671 et seq., contending that defendant government was negligent in failing to protect her from excessive exposure to nitroglycerin. The district court rendered judgment in favor of Stoleson for her heart attack but refused to award damages for the physical manifestations of hypochondria. Stoleson challenged the judgment, contending that her development of hypochondria was the direct result of the heart attack caused by the government's negligence.
Was the government liable for any pre-existing conditions of Stoleson that might have been aggravated by government's negligence?
The Court noted that Stoleson was required to establish a causal connection between her hypochondria and the government's negligence. The Court additionally noted that the egg-shell skull doctrine applied, in that government took Stoleson as she was found; hence, the government was liable for any pre-existing conditions of Stoleson that might have been aggravated by government's negligence. However, the Court held that Stoleson had failed to establish any causal connection between her continuing physical symptoms and defendant's negligence. Therefore, the judgment was affirmed.
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