Key Takeaway
Court establishes triable issue of fact on causation in personal injury case, highlighting importance of medical expert testimony and comparative MRI evidence.
Understanding Causation in Personal Injury Cases: When Medical Evidence Creates Questions for Trial
Establishing causation between an accident and claimed injuries remains one of the most critical elements in personal injury litigation. The challenge becomes particularly complex when plaintiffs have pre-existing conditions or prior injuries to the same body part. Courts must carefully evaluate whether new symptoms following an accident represent a genuine causal relationship or merely coincidental timing.
The Second Department’s decision in Vargas v Marte demonstrates how proper medical expert testimony, supported by objective evidence, can successfully overcome summary judgment motions even when pre-existing conditions are present. This case illustrates the delicate balance courts strike when determining whether causation issues have been broken by intervening factors or prior medical history.
Jason Tenenbaum’s Analysis:
Vargas v Marte, 2014 NY Slip Op 08561 (2d Dept. 2014)
Triable issue of fact on causation
“In particular, plaintiff’s surgeon, recognizing that plaintiff had sustained a prior left knee injury and some age-related degeneration, opined, following his review of plaintiff’s MRIs from before and after the accident, that the lack of left knee pain prior to the accident, coupled with the acute onset of pain after the accident, showed that plaintiff’s left knee meniscal tears were causally related to the subject accident”
Assuming you do not have the MRI’s, would the remainder of the passage be sufficient to defeat summary judgment? Unsure – but probably yes in light of Perl.
Key Takeaway
Medical expert testimony that acknowledges pre-existing conditions while establishing a clear temporal relationship between an accident and new symptoms can create triable issues of fact on causation. The combination of objective imaging evidence and symptom onset timing provides courts with sufficient grounds to deny summary judgment, even when prior injuries exist to the same anatomical area.
Legal Update (February 2026): Since this post was published in 2014, New York courts have continued to refine causation standards in personal injury cases, particularly regarding pre-existing conditions and the sufficiency of medical expert testimony. Practitioners should verify current case law developments and any updates to medical expert qualification requirements under the Civil Practice Law and Rules that may affect causation analysis in similar cases.
