Blatz v. Allina Health System
Minnesota Court of Appeals
622 N.W.2d 376 (2001)
Mary Blatz (plaintiff) suffered a heart attack at home, and Allina's (defendant) paramedics arrived several minutes late after getting lost, by which point she had no pulse. She survived but suffered permanent brain damage from lack of oxygen. Blatz sued Allina for negligence, arguing that the paramedics' delay cost her the crucial window in which resuscitation could have prevented the brain damage; Allina's experts countered that the damage had already occurred before any paramedic could have arrived. The trial judge instructed the jury to hold Allina liable only for damages its negligence caused, but to hold it liable for everything if the damages from the heart attack and the delay could not be separated. The jury awarded Blatz $11 million, and Allina appealed the instruction.
Whether a tortfeasor may be held liable for all of a plaintiff's damages when damages caused by the plaintiff's preexisting condition cannot be separated from damages caused by the tortfeasor.