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Benn v. Thomas

512 N.W.2d 537 (Iowa 1994)

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Benn v. Thomas

Iowa Supreme Court

512 N.W.2d 537 (Iowa 1994)

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Facts

Benn suffered a bruised chest and broken ankle after Thomas (defendant) rear‑ended Benn’s vehicle. Benn died of a heart attack six days later, and Benn’s estate (plaintiff) sued. Benn had a history of coronary disease, diabetes, had suffered a heart attack, and was at risk of having another. The medical evidence presented at trial was divided as to whether the accident caused Benn’s death. Benn’s estate requested that the trial judge instruct the jury on the eggshell plaintiff rule. The trial judge instead instructed the jury to determine proximate cause based on whether the accident was a substantial factor in Benn’s death. The jury found that Thomas’s negligence was not the proximate cause of Benn’s death. The court of appeals reversed, based on the trial court’s refusal to instruct on the eggshell plaintiff rule.

Rule of Law

Issue

Holding and Reasoning (McGiverin, C.J.)

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