Scafidi v. Seiler
New Jersey Supreme Court
119 N.J. 93, 574 A.2d 398 (1990)
- Written by Liz Nakamura, JD
Facts
Jamie Scafidi (plaintiff) went into preterm labor, which Dr. F. Seiler (defendant) failed to properly treat. Scafidi’s baby was born prematurely and died shortly after birth. Scafidi filed a medical-malpractice action against Seiler, arguing that Seiler’s negligent treatment had caused her baby’s death. At trial, the court refused Scafidi’s requests to (1) instruct the jury on the increased-risk standard of causation in medical-malpractice cases or (2) instruct the jury that damages could be apportioned only if Seiler could prove that Scafidi’s preexisting condition, meaning her preterm labor, could have independently caused her baby’s death regardless of Seiler’s negligence. The jury found Seiler negligent but absolved Seiler of liability, finding that Seiler’s negligence was not the proximate cause of the baby’s death. Scafidi appealed. On appeal, the appellate court (1) affirmed the trial court’s refusal to instruct the jury on apportionment of damages but (2) held that the trial court had committed reversible error by failing to apply the increased-risk standard of causation. The New Jersey Supreme Court granted certification.
Rule of Law
Issue
Holding and Reasoning (Stein, J.)
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