Key Takeaway
New York Court of Appeals case demonstrates how timing gaps between accidents and medical complaints can break the causal chain in personal injury claims.
Establishing causation between an accident and claimed injuries is fundamental to any successful personal injury case in New York. The temporal relationship between an incident and the manifestation of symptoms plays a crucial role in determining whether a plaintiff can prove their injuries resulted from the defendant’s negligence.
In personal injury litigation, defendants often challenge causation by pointing to gaps in medical treatment or delays in reporting symptoms. Courts scrutinize the timeline carefully, as extended periods between an accident and medical complaints can suggest alternative causes for the plaintiff’s condition. This principle protects defendants from liability for pre-existing conditions or injuries that may have developed independently after the incident.
The timing element becomes particularly important when evaluating the strength of causation arguments in cases involving multiple potential causes. Medical records serve as critical evidence, and any inconsistencies or gaps can significantly impact a case’s outcome. Understanding how courts analyze these temporal relationships helps both plaintiffs and defendants assess the viability of their positions in personal injury claims.
Jason Tenenbaum’s Analysis:
Jones v MTA Bus Co., 2014 NY Slip Op 08915 (1st Dept. 2014)
As for plaintiff’s other claimed injuries, defendants met their burden by relying on plaintiff’s testimony that her eye stopped hurting within weeks of the accident, and her post-accident hospital and medical records showing that she made no complaints until about five months after the accident, which was too remote in time to establish a causal relationship (see Rosa v Mejia, 95 AD3d 402, 404 ).
There was a bit more to the case but this is the snippet that has relevance to me.
Key Takeaway
The Jones case illustrates a fundamental principle in New York personal injury law: timing matters critically in establishing causation. When plaintiffs fail to seek medical attention or report symptoms for extended periods after an accident, courts may find the temporal gap too significant to support a causal connection. This five-month delay between the accident and medical complaints proved fatal to the plaintiff’s claim, demonstrating why prompt medical attention and consistent documentation are essential elements of any injury case.
Legal Update (February 2026): Since this post’s publication in December 2014, New York’s causation standards and evidentiary requirements in personal injury cases may have evolved through subsequent appellate decisions and statutory amendments. Practitioners should verify current case law precedents and any updates to medical record authentication requirements or expert testimony standards that may affect causation analysis in personal injury litigation.
