Crinkley v. Holiday Inns, Inc.
United States Court of Appeals for the Fourth Circuit
844 F.2d 156 (1988)
The Crinkleys (plaintiffs) were violently assaulted at gunpoint at a Holiday Inn (defendant) that had declined to hire extra security despite recent, similar armed robberies at nearby motels and a specific warning from local police; Sarah suffered a heart attack 14 months later and was later diagnosed with PTSD, and expert testimony attributed both conditions primarily to the stress of the assault, leading a jury to award substantial compensatory damages that Holiday Inn challenged as insufficiently connected to the original negligence.
Whether a plaintiff may recover for personal injuries even if there is a significant time gap between the negligence and the injury, provided there is evidence of causation.