Lancaster v. Norfolk and Western Railway Co.

Gary Lancaster (plaintiff), a longtime mechanic for Norfolk and Western Railway (defendant), endured years of abuse from a series of aggressive foremen starting in 1975, including one who threatened him with a broom handle and another who swung a sledgehammer near his head, leaving him increasingly paranoid and occasionally hallucinating. In 1979, a final foreman charged at him wielding a pickax handle, striking the doorframe above his head; badly shaken, Lancaster was diagnosed as schizophrenic just two weeks later and was never expected to work again. At trial, three experts agreed the pickax assault triggered his schizophrenia, though one testified that something else likely would have triggered it eventually even without that incident; the judge declined to instruct the jury to discount damages for that possibility, instead instructing more generally that the jury should award damages for injuries the railroad actually caused. The jury awarded Lancaster $850,000, and Norfolk appealed the damages instruction.