Stoleson v. United States

Helen Stoleson (plaintiff) worked for a federal munitions plant, where she regularly handled nitroglycerin. Regular exposure to nitroglycerin caused Stoleson to have heart disease. In February 1968, Stoleson was diagnosed with having a possible heart attack. In 1971 Stoleson saw Dr. Lange, who determined the nitroglycerin exposure caused her disease and told her she had serious, permanent heart damage. Stoleson left the munitions plant in 1971, and her heart disease eventually resolved with no lasting effect. Stoleson filed suit against the federal government under the Federal Tort Claims Act. In 1975 the first trial was held. A second trial was held in the early 1980s on the issue of damages, with Stoleson seeking damages for the heart disease as well as hypochondria symptoms, including dizziness, chest pains, and other symptoms that made her unable to work. Hypochondria was not mentioned in the first trial. Dr. Goldbloom, a psychiatrist, evaluated Stoleson in 1980, and he testified at trial that Stoleson had hypochondria that had been induced by her possible heart attack in 1968. Dr. Goldbloom also testified that the hypochondria’s onset was triggered by Dr. Lange’s diagnosis in 1971. Dr. Roberts, the government’s psychiatrist, examined Stoleson in 1981, and he testified that Stoleson had been a hypochondriac her whole life. One psychiatrist testified that hypochondria is difficult to diagnose because so little is known about it. The judge found that the government’s negligence caused Stoleson’s heart disease and awarded her $53,000 in damages. The judge did not award damages for her hypochondria symptoms, holding that Stoleson had not proved causation or that her symptoms had occurred before the first trial in 1975, but he found that if she had proven causation, her damages would be $238,000. Stoleson appealed.