Follett v. Jones
Arkansas Supreme Court
481 S.W.2d 713 (1972)
Frank Follett (defendant) collided with a truck driven by Chauncy Jones, who was hospitalized with injuries and, incidentally, discovered during treatment to have terminal lung cancer; Jones died 17 days later, with cancer listed as the cause of death, though doctors testified the accident combined with the cancer to cause death and hastened his passing. A jury found Follett negligent and awarded Jones's widow wrongful-death damages. Follett appealed, arguing the evidence didn't establish the collision as the actual cause of death and that the damages award was speculative because no evidence quantified how much the accident shortened Jones's remaining life.
Whether damages for negligence should reflect the likelihood that the plaintiff would have suffered the same injury (or death) from other causes absent the defendant's negligence.