causation inquiry (Louisiana) · Go Syfert
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causation inquiry in Louisiana

24 Louisiana opinions name it 2 courts 1984–2019 0 in the last five years

The cases below were cited by Louisiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
LaCaze v. Colliergreen
la · 1983 · cited in 4 Louisiana opinions naming this issue, 1984–2010
2 sentences

2010In a no consent case that involves no physical damages, "the usual causation inquiry into whether a reasonable person in the patient’s position would have consented if he or she had known of the risk that materialized is not applicable.” Lugenbuhl , 96-1575 at p. 14, 701 So.2d at 455, n. 9 ; LaCaze v. Collier, 434 So.2d 1039, 1040, n. 1 (La.6/17/83)(noting that in a case where the plaintiff alleges there has been no consent, the law requires only proof of a material risk that was not disclosed and the occurrence of that risk.) .

1984The causation test was outlined by the Supreme Court in LaCaze v. Collier, supra, as follows: Lack of valid consent gives rise to an action for damages.

34
Jones v. Trailorgreen
lactapp · 1994 · cited in 2 Louisiana opinions naming this issue, 2019–2019
2 sentences

2019See Jones v. Trailor , 1993-2144 (La.App. 4 Cir. 4/28/94) , 636 So.2d 1112 , 1118.

2019See Jones v. Trailor , 1993-2144 (La.App. 4 Cir. 4/28/94) , 636 So.2d 1112 , 1118.

22
Lugenbuhl v. Dowlinggreen
la · 1997 · cited in 4 Louisiana opinions naming this issue, 2005–2010
2 sentences

2010In a no consent case that involves no physical damages, "the usual causation inquiry into whether a reasonable person in the patient’s position would have consented if he or she had known of the risk that materialized is not applicable.” Lugenbuhl , 96-1575 at p. 14, 701 So.2d at 455, n. 9 ; LaCaze v. Collier, 434 So.2d 1039, 1040, n. 1 (La.6/17/83)(noting that in a case where the plaintiff alleges there has been no consent, the law requires only proof of a material risk that was not disclosed and the occurrence of that risk.) .

2005However, in a no-consent case that involves no physical damages, "the usual causation inquiry into whether a reasonable person in the patient's position would have consented if he or she had known of the risk that materialized is not applicable.. . ." Lugenbuhl, supra .

14
Jenkins v. Sonat Offshore USA Inc.green
lactapp · 1997 · cited in 2 Louisiana opinions naming this issue, 2004–2004
2 sentences

2004See Jenkins v. Sonat Offshore U.S.A., Inc., *488 96-2504 (La.App. 1 Cir. 12/29/97) , 705 So.2d 1184, 1187 .

2004Jenkins v. Sonat Offshore U.S.A., Inc., 96-2504, p. 3 (La.App. 1 Cir. 12/29/97), 705 So.2d 1184, 1187 .

12
McCastle v. Rollins Environmental Services of La., Inc.green
la · 1984 · cited in 1 Louisiana opinions naming this issue, 1997–1997
1 sentence

1997Because the plaintiffs have failed to demonstrate a common character of their claims, we cannot say that certification of a class action would achieve "economies of time, effort, and expense, and promote uniformity of decision as to persons similarly situated, without sacrificing procedural *1173 fairness or bringing about other undesirable results." McCastle v. Rollins Environmental Services of Louisiana, Inc., 456 So.2d 612, 616 (La.1984).

11
Canizaro v. Kohlmeyer & Companygreen
laed · 1974 · cited in 1 Louisiana opinions naming this issue, 1990–1990
2 sentences

1990We quote from Canizaro v. Kohlmeyer & Co., 370 F.Supp. 282 (E.D.La.1974), aff'd, 512 F.2d 485 (5th Cir.1975): ... [T]he line of demarcation must be drawn in terms of cause and effect: To borrow a phrase from the law of negligence, did the injury to the plaintiff flow directly and proximately from the actions of this particular defendant? *917 Canizaro , at 287, citing Hill York Corp. v. American International Franchises, 448 F.2d 680 (5th Cir.1971).

1990We quote from Canizaro v. Kohlmeyer & Co., 370 F.Supp. 282 (E.D.La.1974), aff'd, 512 F.2d 485 (5th Cir.1975): ... [T]he line of demarcation must be drawn in terms of cause and effect: To borrow a phrase from the law of negligence, did the injury to the plaintiff flow directly and proximately from the actions of this particular defendant? *917 Canizaro , at 287, citing Hill York Corp. v. American International Franchises, 448 F.2d 680 (5th Cir.1971).

11
Holland v. Buckleygreen
la · 1974 · cited in 1 Louisiana opinions naming this issue, 1986–1986
1 sentence

1986Victim fault was recognized as a defense to a C.C. 2321 strict liability action in Holland v. Buckley, supra at 117-18.

11
Guidry v. Sline Indus. Painters, Inc.green
la · 1982 · cited in 1 Louisiana opinions naming this issue, 1985–1985
2 sentences

1985(Brackets supplied.) In Guidry v. Sline Industrial Painters, Inc., 418 So.2d 626, 633 (La.1982), Calogero, J., for the Court, stated the causation requirement, in part, as follows: For the heart accident to arise out of or be connected with the employment, the exertion[,] stress or strain, acting upon the pre-existing disease, must be of a degree greater than that generated in every-day non-employment life (e.g., as compared to the more or less sedentary life of the average non-worker). ... [I]f the activities in which the worker with a pre-existing heart disease is engaged, whether for his jo

1985(Brackets supplied.) Guidry, supra, at 633 , makes it clear that the burden of proving the causal link between the employment and the accident has not been altered.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Louisiana. Read the followed side critically anyway.

Also cited on this issue (16)

CaseCitedYears
Zimko v. American Cyanamid green
lactapp · 2005
2 sentences

2015Zimko v. American Cyanamid, 2003-0658, p. 26 (La.App. 4 Cir. 6/8/05), 905 So.2d 465, 485 , writ denied, 2005-2102 (La.3/17/06), 925 So.2d 538 .

2006Zimko v. American Cyanamid , XXXX-XXXX, p. 26 (La.App. 4 Cir. 6/8/05), 905 So.2d 465, 485 , writ denied, 2005-2102 (La.3/17/06), 925 So.2d 538 .

22006–2015
Zimko v. American Cyanamid green
la · 2006
2 sentences

2015Zimko v. American Cyanamid, 2003-0658, p. 26 (La.App. 4 Cir. 6/8/05), 905 So.2d 465, 485 , writ denied, 2005-2102 (La.3/17/06), 925 So.2d 538 .

2006Zimko v. American Cyanamid , XXXX-XXXX, p. 26 (La.App. 4 Cir. 6/8/05), 905 So.2d 465, 485 , writ denied, 2005-2102 (La.3/17/06), 925 So.2d 538 .

22006–2015
State v. Small green
la · 2012
1 sentence

2017However, in Small, the Supreme Court was generally addressing the type of causal connection the State must show between a defendant’s conduct and the victim’s death for a defendant to be criminally culpable “where multiple causes led to the death.” Small, 100 So.3d at 812 .

12017–2017
Maranto v. Goodyear Tire & Rubber Co. green
la · 1995
1 sentence

2002The plaintiff's burden of proof of causation in a personal injury case was set forth by our Supreme Court in Maranto v. Good-year Tire & Rubber Co., 94-2603, p. 3 (La.2/20/95), 650 So.2d 757, 759 , as follows: In a personal injury suit, plaintiff bears the burden of proving a causal relationship between the injury sustained and the accident which caused the injury.

12002–2002
cluster 718203 green
ca3 · 1996
2 sentences

1997Each has a different history of cigarette smoking, a factor that complicates the causation inquiry.... ___ U.S. at ___, 117 S.Ct. at 2250 (citing 83 F.3d 610, 626 ).

1997These factors were highlighted by the Third Circuit "[i]n contrast to mass torts involving a single accident." The Court did find that "mass tort cases arising from a common cause or disaster may, depending upon the circumstances, satisfy the predominance requirement." Id.

11997–1997
Charles D. Gautreaux v. Scurlock Marine, Inc. green
ca5 · 1997
1 sentence

1997As the Fifth Circuit indicated in Gautreaux, 107 F.3d 331 , the Jones Act contains a liberal causation requirement.

11997–1997
Amchem Products, Inc. v. Windsor green
scotus · 1997
1 sentence

1997Each has a different history of cigarette smoking, a factor that complicates the causation inquiry.... ___ U.S. at ___, 117 S.Ct. at 2250 (citing 83 F.3d 610, 626 ).

11997–1997
Barry Brister and Karen Brister, Cross-Appellees v. A.W.I., Inc., Cross-Appellants green
ca5 · 1991
1 sentence

1995Brister v. A.W.I., Inc., 946 F.2d 350 (5th Cir.1991), rehearing denied, 949 F.2d 1160 (5th Cir. 1991).

11995–1995
Brister (Barry, Karen) v. A.W.I., Inc neutral
ca5 · 1991
1 sentence

1995Brister v. A.W.I., Inc., 946 F.2d 350 (5th Cir.1991), rehearing denied, 949 F.2d 1160 (5th Cir. 1991).

11995–1995
Sinitiere v. Lavergne green
la · 1980
1 sentence

1990Sinitiere v. Lavergne, supra ; Fowler v. State Farm Fire & Casualty Insurance Co., supra .

11990–1990
Fed. Sec. L. Rep. P 93,213 Hill York Corporation v. American International Franchises, Inc., Gurn H. Freeman green
ca5 · 1971
1 sentence

1990We quote from Canizaro v. Kohlmeyer & Co., 370 F.Supp. 282 (E.D.La.1974), aff'd, 512 F.2d 485 (5th Cir.1975): ... [T]he line of demarcation must be drawn in terms of cause and effect: To borrow a phrase from the law of negligence, did the injury to the plaintiff flow directly and proximately from the actions of this particular defendant? *917 Canizaro , at 287, citing Hill York Corp. v. American International Franchises, 448 F.2d 680 (5th Cir.1971).

11990–1990
George Brown v. Harlan E. O'leary, the First National Bank of Hereford, Hereford, Texas, and William P. Maroski green
ca1 · 1975
1 sentence

1990We quote from Canizaro v. Kohlmeyer & Co., 370 F.Supp. 282 (E.D.La.1974), aff'd, 512 F.2d 485 (5th Cir.1975): ... [T]he line of demarcation must be drawn in terms of cause and effect: To borrow a phrase from the law of negligence, did the injury to the plaintiff flow directly and proximately from the actions of this particular defendant? *917 Canizaro , at 287, citing Hill York Corp. v. American International Franchises, 448 F.2d 680 (5th Cir.1971).

11990–1990
Mitchell v. Employers Mutual Liability Ins. Co. of Wisconsin neutral
la · 1977
1 sentence

1988Lisonbee v. Chicago Mill and Lumber Co., 278 So.2d 5 (La.1973); Mitchell v. Employers Mutual Liability Insurance Co., 341 So.2d 35 (La.App. 3rd Cir.1977), cert. denied 342 So.2d 1121 (Watson, J., concurring); Raybol v. Louisiana State University, 520 So.2d 724 (La.1988). [3] The record does not indicate any employment requirement that plaintiff had to be treated by the company doctor. [4] From the standpoint of a normal causation analysis in tort cases, the tort liability of the original tortfeasor extends to a worsening of the initial injury by negligent medical treatment, because the risk in

11988–1988
Lisonbee v. Chicago Mill and Lumber Company green
la · 1973
1 sentence

1988Lisonbee v. Chicago Mill and Lumber Co., 278 So.2d 5 (La.1973); Mitchell v. Employers Mutual Liability Insurance Co., 341 So.2d 35 (La.App. 3rd Cir.1977), cert. denied 342 So.2d 1121 (Watson, J., concurring); Raybol v. Louisiana State University, 520 So.2d 724 (La.1988). [3] The record does not indicate any employment requirement that plaintiff had to be treated by the company doctor. [4] From the standpoint of a normal causation analysis in tort cases, the tort liability of the original tortfeasor extends to a worsening of the initial injury by negligent medical treatment, because the risk in

11988–1988
Raybol v. Louisiana State University green
la · 1988
1 sentence

1988Lisonbee v. Chicago Mill and Lumber Co., 278 So.2d 5 (La.1973); Mitchell v. Employers Mutual Liability Insurance Co., 341 So.2d 35 (La.App. 3rd Cir.1977), cert. denied 342 So.2d 1121 (Watson, J., concurring); Raybol v. Louisiana State University, 520 So.2d 724 (La.1988). [3] The record does not indicate any employment requirement that plaintiff had to be treated by the company doctor. [4] From the standpoint of a normal causation analysis in tort cases, the tort liability of the original tortfeasor extends to a worsening of the initial injury by negligent medical treatment, because the risk in

11988–1988
Mitchell v. Employers Mut. Liability Ins. Co. green
lactapp · 1977
1 sentence

1988Lisonbee v. Chicago Mill and Lumber Co., 278 So.2d 5 (La.1973); Mitchell v. Employers Mutual Liability Insurance Co., 341 So.2d 35 (La.App. 3rd Cir.1977), cert. denied 342 So.2d 1121 (Watson, J., concurring); Raybol v. Louisiana State University, 520 So.2d 724 (La.1988). [3] The record does not indicate any employment requirement that plaintiff had to be treated by the company doctor. [4] From the standpoint of a normal causation analysis in tort cases, the tort liability of the original tortfeasor extends to a worsening of the initial injury by negligent medical treatment, because the risk in

11988–1988

Statutes the citing opinions construe

LA § La. Rev. Stat. § 40:1299.40 (7) LA § La. Rev. Stat. § 9:2794 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 252 (1978–2026) CA 161 (1978–2026) PA 61 (1952–2026) IL 49 (1980–2025) IA 48 (1982–2023) MI 47 (1988–2026) MO 40 (1989–2024) OH 33 (1991–2023) UT 30 (1986–2026) MA 28 (1980–2025) OR 28 (1990–2024) NY 27 (1933–2024) MD 26 (1977–2022) AL 26 (1981–2025) MN 25 (1987–2026) LA 24 (1984–2019) NM 23 (1938–2024) CT 22 (1991–2025) WA 22 (1983–2023) FL 21 (1984–2025) NJ 19 (1990–2026) WI 19 (1995–2024) GA 18 (1902–2025) SD 16 (1992–2020) VA 13 (1988–2024) CO 13 (1984–2020) AZ 13 (1997–2024) AK 12 (1988–2022) DC 12 (1990–2024) ID 12 (2005–2026) MT 11 (1990–2022) IN 11 (1986–2026) TN 11 (1997–2019) VT 10 (1991–2024) NC 10 (1988–2020) HI 9 (1995–2018) KS 9 (1991–2025) ME 8 (1982–2021) WY 8 (1982–2013) NE 8 (1996–2026) RI 7 (1993–2008) NH 7 (1986–2021) MS 7 (1992–2011) AR 6 (1999–2025) DE 4 (2014–2024) KY 3 (2006–2026) WV 2 (1997–2001) NV 2 (2012–2026) OK 2 (1981–2016) ND 2 (1994–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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