Steinhauser v. Hertz Corporation
United States Court of Appeals for the Second Circuit
421 F.2d 1169 (1970)
Fourteen-year-old Cynthia Steinhauser (plaintiff) was in a car accident caused by Ponzini (defendant), driving a car owned by Hertz Corporation (defendant). She suffered no physical injuries in the crash, but within minutes began acting strangely, soon becoming agitated, depressed, and suicidal -- behavior she had never shown before. She was later diagnosed with schizophrenia with a poor prognosis. At trial, experts testified she had a predisposition to schizophrenia and that the accident was a precipitating cause of the illness manifesting. The district court ruled for the defendants, and Steinhauser appealed.
Whether a defendant's negligence is the proximate cause of a plaintiff's harm when it precipitates the onset of a pre-existing condition, rather than being the sole underlying cause of that condition.