Brauer v. New York Central & H.R.R. Co.
New Jersey Supreme Court
103 A. 166 (N.J. 1918)
Brower (plaintiff), driving a commercial horse-drawn wagon carrying barrels, was struck at a grade-crossing by a train operated by New York Central & H.R.R. (railroad) (defendant); the horse was killed, the wagon destroyed, and the barrels scattered on the ground, leaving Brower stunned and unable to react. Shortly after the crash, thieves stole the scattered barrels — a risk the railroad had apparently anticipated, since it employed two engineers specifically to guard against theft after accidents, though they weren't able to prevent this particular theft. Brower sued the railroad for both his physical injuries and the value of the stolen cargo.
Whether a negligent defendant who injures a plaintiff is liable for the full extent of the plaintiff's injuries when those injuries are made worse by a third party's foreseeable intervening act.