## Facts

- Helen J. Stoleson worked (1967–1971) at a federally owned munitions plant operated by a private contractor; her duties involved handling nitroglycerin.
- Within months, she developed chest pains occurring primarily on weekends; in February 1968 she was hospitalized for a suspected myocardial infarction or coronary insufficiency.
- After leaving the plant, she sought medical support for the theory that workplace nitroglycerin exposure and weekend withdrawal caused her cardiac episode and symptoms; one physician (Dr. Lange) accepted this explanation and warned her of serious, possibly permanent heart damage.
- In 1974, Stoleson sued the United States under the Federal Tort Claims Act (FTCA), alleging negligent failure to protect workers from excessive nitroglycerin exposure.
- After an initial dismissal on limitations grounds was reversed, the case was retried in 1981.
- At the retrial, the government conceded negligence and causation as to Stoleson’s organic heart disease; the court awarded $53,000 for that injury.
- Stoleson also sought damages for continuing psychosomatic and hypochondriacal symptoms (e.g., dizziness, chest pain, shortness of breath, fear of heart trouble) that persisted after the organic condition resolved.
- Competing psychiatric testimony addressed whether her hypochondriasis was triggered by the nitroglycerin-related cardiac episode and subsequent medical warnings (plaintiff’s expert) or reflected a preexisting lifelong condition unrelated to the negligence (government’s expert).
- The district court denied damages for the hypochondriacal/psychosomatic condition for lack of proven causation and suggested, alternatively, that recovery required proof the condition existed before the first trial; the court also found that, if causation were proven, damages for the psychological condition would be $238,000.

## Issues

1. Whether, under the FTCA, the United States may be liable for hypochondriasis and psychosomatic symptoms that continued after the organic heart disease resolved when those psychological injuries were allegedly set in motion by the conceded negligence.
2. Whether the district court clearly erred in finding that Stoleson failed to prove causation between the negligence and her hypochondriacal/psychosomatic condition.
3. Whether recoverable damages could be limited by a procedural cutoff tied to an earlier trial date rather than by ordinary tort causation and proof.

## Decision

- Affirmed the finding of negligence and the $53,000 award for organic heart injury.
- Reversed the denial of damages for hypochondriasis/psychosomatic sequelae, holding the causation finding was clearly erroneous on this record.
- Rejected a rigid limitation that would bar recovery for psychological consequences merely because they were not shown to exist before a prior trial.
- Remanded with instructions to enter judgment including the additional $238,000 the district court had conditionally found for the psychological injury.

## Legal Principles

- A tortfeasor is liable for reasonably foreseeable psychological injuries that result from negligently inflicted physical harm, even if the physical condition later resolves.
- Proximate causation does not require foresight of the precise psychiatric diagnosis; it is enough that some psychological reaction to a serious injury and alarming medical information is a foreseeable consequence of the negligence.
- The defendant takes the plaintiff as found; preexisting psychological susceptibility does not cut off liability if the negligence triggers or aggravates the condition.
- Damages for consequences proximately caused by negligence are not confined by litigation milestones (such as the date of an earlier trial) but by substantive tort principles and proof of causation and extent.

## Conclusion

The Seventh Circuit held that the United States was liable under the FTCA not only for Stoleson’s nitroglycerin-related organic heart injury but also for foreseeable, causally connected hypochondriasis and psychosomatic symptoms that persisted after the organic condition resolved, and it directed entry of judgment adding the trial court’s contingent $238,000 psychological-damages figure.


Stoleson v. United States, 708 F.2d 1217 (7th Cir. 1983)