Evidence of Causation is Critical in North Carolina Personal Injury Cases, Says the Court in Martin v. St. Dominic Memorial Hospital

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Martin (“plaintiff”) was at St. Dominic Memorial Hospital (“SDH” or “Defendant”) for a group therapy session when she slipped and fell on the floor. At the time that she fell, the floor was being waxed. Plaintiff alleges that she suffered injuries to both of her knees and sued SDH under the legal cause of action for negligence as a result of the slip and fall accident.

The issue the court confronted in Martin v. St. Dominic Memorial Hospital was whether the plaintiff presented sufficient evidence to support her argument that SDH was negligent. In order to prove negligence, the plaintiff has the burden of proving each of the four elements of negligence.

The plaintiff must show that the defendant owed the plaintiff a specific duty of care. The second component of negligence the plaintiff must prove is that the defendant breached this specific duty of care. This breach of duty can include any affirmative actions by the defendant and can even include omissions for which the defendant was responsible. The third critical element of negligence is that the plaintiff must prove that the defendant’s breach of duty was directly and proximately the cause of the plaintiff’s injuries. To prove this the plaintiff must provide evidence of the direct causal link between defendant’s actions or failure to act and the plaintiff’s damages. The last element involved in a case for negligence is that the plaintiff must provide the court with evidence of the actual damages.

The court held that where a plaintiff fails to provide sufficient evidence and prove the elements of negligence it is proper to grand a directed verdict for the defendant.

The court looked to several factors in their analysis of the case at hand. It can be found that the plaintiff had actual knowledge that the floor was being waxed because the plaintiff was passing the custodian who was waxing the floor when she fell. Then the defendant provided evidence that plaintiff and other members of the group were warned to avoid the hallway because it was being waxed. Additionally, the court notes that SDH had placed warning signs in the area that was being waxed.

On the other hand, plaintiff testified alleging that there were no warning signs on display and that the group was never warned that the floor was being waxed. Plaintiff argued that because of her fall at SDH, she suffered serious swelling and injury to her knees. But the court notes that the plaintiff had previously suffered from arthritis in both of her knees.

The only way to decipher the element of causation is to have the testimony of a medical expert. However, the court found the testimony of the expert was insufficient to prove the causal link. Evidence was presented to the court showing that plaintiff had a meniscus tear in her knee which could have been caused by an injury or because of wear and tear.

The court explained that the plaintiff had to provide evidence that her injuries were the result of her fall at SDH or that her fall at SDH aggravated a preexisting condition. Basically, the court said that a reasonable jury would be unable to decipher whether plaintiff’s injury was the cause of her arthritis or the fall at SDH. Because the doctor was not able to provide his opinion with sufficient certainty, the causal link between defendant’s actions and the injury plaintiff suffered is too weak.

This case illustrates how critical it is to have the right information presented in support of your claim.

If you have been injured contact North Carolina injury attorneys at Lee Law Offices to schedule a free appointment today. Call 800-887-1965.

Additional Resources:

Martin v. St. Dominic Memorial Hospital, No. 2009-CT-01365-SCT (Miss. S.Ct. Apr. 4, 2012).

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