Williams v. Chrysler First Fin. Servs. Co.
2017 Ohio 7778
| Ohio Ct. App. | 2017Background
- In Oct. 2014 Charmalita Williams began repetitive overhead work for FCA/Chrysler installing door pads and developed right shoulder pain about five weeks later.
- She was diagnosed with a full-thickness right rotator cuff tear and filed a workers’ compensation claim for that injury.
- Two medical experts testified at trial: Williams’ treating physician (Dr. Sohn) and an independent examiner (Dr. Gula). Both agreed Williams had preexisting shoulder conditions (Type II acromion, bone spur, AC joint arthritis) and a full-thickness tear, but disagreed on causation.
- Dr. Sohn opined the tear resulted from a work-related overuse mechanism, with the preexisting conditions acting as risk factors that combined with repetitive work. Dr. Gula testified the tear was chronic/natural deterioration and the preexisting conditions were only predisposing factors.
- Williams requested a dual-causation jury instruction (an injury may have more than one proximate cause when factors combine); the trial court denied it, instead giving an "eggshell plaintiff" instruction. Jury disallowed her claim; Williams appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a dual-causation jury instruction was warranted | Williams: expert testimony shows her preexisting conditions combined with repetitive work to cause the tear, so each factor should be treated as a proximate cause | Chrysler: experts described preexisting conditions as mere predisposing risk factors and offered competing single-cause theories (work overuse v. natural deterioration) — no evidence of multiple proximate causes | Court: No error in refusing instruction; neither expert identified more than one proximate cause and record supports competing single-cause theories rather than dual causation |
| Whether the eggshell-plaintiff instruction made a dual-causation instruction improper or redundant | Williams: experts’ combined-factor language supports dual causation despite not using the precise phrase "proximate cause" | Chrysler: predisposition/risk-factor evidence is properly addressed by eggshell instruction; dual causation and eggshell plaintiff are inconsistent | Court: The eggshell-plaintiff instruction was given; if evidence supports eggshell rule it cannot simultaneously support dual causation, so dual-causation instruction was not required |
Key Cases Cited
- Murphy v. Carrollton Mfg. Co., 61 Ohio St.3d 585 (Ohio 1991) (dual-causation instruction appropriate only when evidence shows more than one proximate cause)
- Aiken v. Industrial Comm., 143 Ohio St. (Ohio) (proximate cause definition applies in workers’ compensation context)
- Cook v. Mayfield, 45 Ohio St.3d 200 (Ohio 1989) (burden to show injury arose out of and in course of employment)
- Swanton v. Stringer, 42 Ohio St.2d 356 (Ohio 1975) (medical testimony need not use legal "magic words"; view testimony in totality)
- Oswald v. Connor, 16 Ohio St.3d 38 (Ohio 1985) (same principle regarding medical causation testimony)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (abuse-of-discretion standard for reviewing trial court decisions)