McCahill v. New York Transportation Co.

Brief Fact Summary.

The decedent’s family sued New York Transportation Company after an alcoholic died following being hit by a taxicab.

Synopsis of Rule of Law.

A defendant can be held responsible for the subsequent effects of his negligent acts due to a plaintiff’s pre-existing condition even without the involvement of the defendant.

Facts.

The decedent, an alcoholic, died of delirium tremens, a condition caused by alcohol withdrawal, after being hit by a taxicab. The decedent’s family (McCahill) sued New York Transportation Company. After a physician’s testimony that the accident accelerated the effects of the victim’s delirium tremens, with no contributory negligence on the part of the decedent, the jury granted judgment in favor of the McCahills. New York Transportation Company appealed.

Issue.

Whether a defendant can be held responsible for the subsequent effects of his negligent acts, without the involvement of the defendant, due to a plaintiff’s pre-existing condition?

Held.

Yes. Affirmed.

Discussion.

A negligent person is responsible for the effects of his negligent acts regardless of whether the victim affected is sick or healthy. Therefore, contributory negligence is not a defense the defendant’s liability because the decedent would have died at a later date if the decedent was never hit by New York Transportation Company. Ultimately, the cab negligently hit the decedent, causing the onset of the decedent’s delirium tremens, and hastened the death of the decedent, attributing full responsibility to New York Transportation Company.