## Facts

- An Ohio Department of Transportation (ODOT) snowplow collided with a vehicle in which Michael Pace was a passenger.
- Pace injured the small finger of his left hand in the collision and also reported neck and back injuries.
- He received initial hospital treatment; early records described the finger injury as swelling and a sprain.
- Over the following days the finger worsened, developing infection and necrosis, and the small finger was amputated on January 15, 1988.
- Pace had diabetes, and medical testimony described diabetes as impairing circulation and wound healing, increasing the risk that minor extremity trauma can progress to severe infection and amputation.
- Michael Pace and his wife, Renee Pace, sued ODOT in the Ohio Court of Claims seeking damages, including for Michael’s injuries and Renee’s derivative loss-of-consortium-type claims.
- ODOT did not materially dispute negligence as to the collision but disputed whether its negligence was the legal cause of the amputation and suggested alternative causes including alleged drug use and inadequate self-care.

## Issues

1. Whether ODOT’s admitted negligence in causing the collision was the proximate cause of Pace’s finger amputation, given his diabetes and alleged intervening or contributory conduct.
2. Whether ODOT was liable for the full extent of the harm under the eggshell-skull rule despite Pace’s pre-existing medical vulnerability.

## Decision

- The Court of Claims entered judgment for Michael and Renee Pace.
- The court found ODOT’s negligent collision proximately caused the amputation.
- The court applied the eggshell-skull rule and held ODOT liable for the full extent of the injury despite Pace’s diabetes.
- The court rejected ODOT’s theories that drug use or poor diabetic management constituted a superseding cause or otherwise defeated causation.
- The court awarded damages to Michael for his injuries and related losses and to Renee on her derivative claim.

## Legal Principles

- Proximate cause turns on whether the injury is a natural and probable result of the negligent act without an intervening superseding cause that breaks the causal chain.
- A tortfeasor takes the plaintiff as found (eggshell-skull rule) and is responsible for the full consequences of an injury even if a pre-existing condition makes the harm more severe than expected.
- Medical causation may be established by evidence linking the negligent trauma to subsequent complications through a continuous progression, even where the progression is worsened by an underlying disease.
- Allegations of plaintiff misconduct or alternative medical explanations do not defeat causation absent reliable evidence showing they caused the ultimate harm or supplanted the original negligence as the operative cause.

## Conclusion

The court held that ODOT’s negligent operation of a snowplow caused a physical injury that, in light of the plaintiff’s diabetes, progressed to infection, necrosis, and amputation; applying the eggshell-skull rule, it imposed liability for the full extent of that harm and awarded damages to the injured plaintiff and his spouse.


Pace v. Ohio Dep’t of Transp., 62 Ohio Misc. 2d 184, 594 N.E.2d 187 (Ct. Cl. 1991)