How Pre-Existing Conditions Affect Personal Injury Damages in Tennessee

When pursuing a personal injury claim in Tennessee, the presence of pre-existing conditions can complicate the process of securing fair compensation. However, the “eggshell plaintiff” doctrine ensures that individuals with pre-existing vulnerabilities are not denied justice simply because of their condition.

This legal principle, alongside Tennessee’s comparative fault rules, influences how damages are calculated and awarded in personal injury cases involving pre-existing conditions.

The “Eggshell Plaintiff” Doctrine Explained

The “eggshell plaintiff” doctrine is a well-established legal principle that protects individuals who may be more prone to injury due to pre-existing conditions or vulnerabilities. The term stems from the idea that a defendant must “take the plaintiff as they find them.” This means that if a negligent party’s actions aggravate an existing condition or cause injury to a particularly vulnerable individual, they can still be held fully liable for the damages caused by their negligence.

For example, if a person with a pre-existing spinal condition is involved in a car accident and their condition worsens significantly due to the collision, the at-fault party is responsible for the full extent of the exacerbation, even if the average person without such a condition might not have sustained as severe an injury. The law recognizes that individuals cannot be penalized for their pre-existing conditions and that defendants should be held accountable for the injuries they cause, regardless of the plaintiff’s prior health status.

While there isn’t a specific Tennessee statute codifying the eggshell plaintiff rule, this principle has been upheld in Tennessee case law. For instance, as far back as 1917 in the case of Elrod v. Franklin, 204 S.W. 298 (Tenn. 1917), the Tennessee Supreme Court affirmed that a defendant is liable for the full extent of the plaintiff’s injuries, even if those injuries are more severe due to a pre-existing condition.

How Pre-Existing Conditions Influence Compensation

While the eggshell plaintiff doctrine ensures protection for vulnerable individuals, the process of determining damages in cases involving pre-existing conditions can be complex. Key factors include the extent to which the pre-existing condition contributed to the plaintiff’s overall injuries, the degree of aggravation caused by the defendant’s actions, and the credibility of medical evidence presented.

Aggravation of Pre-Existing Conditions

Tennessee law distinguishes between injuries directly caused by the defendant’s negligence and pre-existing conditions that were aggravated by the incident. If a plaintiff’s injuries were exacerbated by the defendant’s actions, they are entitled to recover damages for the increased severity of their condition.

For instance, consider a person with a degenerative knee condition who is injured in a slip-and-fall accident caused by unsafe conditions. If the fall accelerates the degeneration or leads to surgery that would not have been immediately necessary, the at-fault party can be held responsible for the costs and suffering related to the aggravated condition.

Proving the Aggravation

To recover damages for the aggravation of a pre-existing condition, plaintiffs must present strong evidence showing that the defendant’s actions directly worsened their condition. This often requires:

Detailed Medical Records: Comparing the plaintiff’s condition before and after the injury helps establish the extent of the aggravation.

Expert Testimony: Medical experts can provide critical insight into how the accident impacted the pre-existing condition, distinguishing between natural progression and aggravation caused by the incident.

Objective Evidence: Diagnostic imaging, such as X-rays or MRIs, can illustrate changes in the plaintiff’s condition following the accident.

Separating Pre-Existing Conditions from New Injuries

In some cases, plaintiffs may have injuries that are entirely unrelated to their pre-existing conditions. For example, a plaintiff with chronic back pain may suffer a broken leg in a car accident. In such instances, the pre-existing condition has no bearing on the claim, and damages are calculated based solely on the new injuries. However, defendants may attempt to argue that all of the plaintiff’s symptoms are related to their prior condition, making it essential to present clear evidence that distinguishes between old and new injuries.

Challenges in Personal Injury Cases with Pre-Existing Conditions

Defendants and insurance companies often exploit the existence of pre-existing conditions to minimize their liability. Common defense strategies include arguing that the plaintiff’s injuries are not as severe as claimed or attributing symptoms entirely to the pre-existing condition. Plaintiffs and their legal teams must be prepared to counter these tactics.

Overcoming “Pre-Existing Condition” Defenses

Comprehensive Medical Documentation: Plaintiffs should provide thorough medical records to establish the baseline of their condition before the injury. These records help demonstrate the degree of change caused by the aggravation.

Clear Causation Evidence: Plaintiffs must connect their aggravated symptoms or new injuries directly to the defendant’s actions. This often involves using expert testimony, such as a medical doctor, to explain the relationship between the accident and the plaintiff’s worsened condition.

Addressing Credibility: Insurance companies may question the plaintiff’s credibility, suggesting they are exaggerating their symptoms. Consistent medical treatment and honest reporting of symptoms are critical to overcoming such claims.

Calculating Damages in Cases Involving Pre-Existing Conditions

Damages in Tennessee personal injury cases can include economic and non-economic losses. In cases with pre-existing conditions, calculating damages requires careful consideration of both the aggravation caused by the incident and the underlying condition.

Economic Damages: Plaintiffs may recover medical expenses related to the aggravation of their condition, such as surgeries, rehabilitation, and additional treatments. Lost wages and diminished earning capacity caused by the worsening condition are also compensable.

Non-Economic Damages: Plaintiffs may seek compensation for pain and suffering, emotional distress, and loss of enjoyment of life caused by the aggravated condition. Courts consider the increased difficulty the plaintiff faces in daily life due to the accident.

No Reduction for Pre-Existing Conditions: Tennessee courts cannot reduce a plaintiff’s compensation simply because they were more vulnerable to injury due to a pre-existing condition. The defendant remains fully liable for the consequences of their negligence.

Contact Fox Farley Willis & Burnette

Personal injury claims involving pre-existing conditions require skilled legal advocacy to ensure fair compensation. An experienced attorney understands how to present medical evidence effectively, counter defense arguments, and calculate damages that reflect the true impact of the injury on the plaintiff’s life.

If you or a loved one has been injured and have pre-existing conditions, it is crucial to protect your rights and secure the compensation you deserve. At Fox Farley Willis & Burnette, we have the experience and knowledge to navigate the complexities of personal injury claims involving pre-existing conditions. Serving clients in Clinton, Gatlinburg, Knoxville, LaFollette, Maryville, Pigeon Forge, and Sevierville, Tennessee, we are committed to helping you achieve justice. Contact us today for a free consultation to discuss your case.

Sources:

law.cornell.edu/wex/eggshell_skull_rule

Elrod v. Franklin, 204 S.W. 298 (Tenn. 1917)