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Lancaster v. Norfolk & Western Railway Co., 773 F.2d 807 (1985)
Supervisor misconduct triggered a worker’s latent schizophrenia. The subsequent lawsuit, Lancaster versus Norfolk and Western Railroad Company, featured a dispute about whether the worker’s damages should be reduced to reflect the likelihood that something else would’ve triggered his schizophrenia eventually.
Gary Lancaster worked as a mechanic for Norfolk and Western Railroad Company. Beginning in 1975, Lancaster was threatened and physically assaulted by a series of short-tempered, aggressive supervisors. This was deeply upsetting to Lancaster and caused him to become paranoid, have trouble working, and occasionally suffer from hallucinations. Eventually, in 1979, one of the supervisors came at Lancaster with a pickax and hit the doorframe above his head. Afterward, Lancaster’s mental condition deteriorated so badly that he was diagnosed with schizophrenia.
No longer fit to work and never expected to recover, Lancaster filed a personal-injury lawsuit against Norfolk in federal district court. At trial, three expert witnesses agreed that the pickax incident triggered Lancaster’s latent schizophrenia. However, one of the expert witnesses was convinced that, if there’d been no supervisor misconduct, something else would’ve triggered Lancaster’s schizophrenia.
The district court declined to instruct the jury to reduce Lancaster’s damages to reflect the likelihood that something other than supervisor misconduct would’ve triggered his latent schizophrenia eventually. Instead, the district court instructed the jury that if the jury found Norfolk liable, then it should award Lancaster all of the damages that the railroad proximately caused. The jury ultimately found Norfolk liable and awarded Lancaster $850,000 in damages. Norfolk appealed to the Seventh Circuit, arguing, in relevant part, that the jury instruction on damages was erroneous.
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