The plaintiff, Ruben Caudle, was employed as a salesman at Bett Lincoln-Mercyry in Louisiana. While at a Christmas party, the defendant engaged in horseplay with an electric automobile condenser, which he used to shock the plaintiff on the back of the neck and chased him with it. The plaintiff was able to escape the defendant by locking himself in an office.
Plaintiff Caudle testified that he developed a headache after leaving the party early and that he experienced frequent and severe headaches and passed out between thirty and forty times in the following months. Nerve blocking shots were unsuccessful in alleviating the headaches and fainting spells, and it was not until the plaintiff's occipital nerve was severed that he was able to find relief, however, after the procedure he suffers from a slight numbness on the right side of his head.
Plaintiff filed suit against Bett and the company individually, seeking damages for past pain and suffering, lost motion and enjoyment of life, past medical expenses, loss of earning, and future damages for the permanent paralysis in his right scalp. After a bench trial, the district court found that the defendant intended to shock the plaintiff but did not intend to injure him beyond a momentary, unpleasant jolt and ruled in favor of the defendant.
Issue: Whether the electrical shock administered as a practical joke constitutes as an intentional tort, and if so, whether the employee may recover damages for the unintended and unforeseeable impairment of his occipital nerve.
Holding: Reversed and remanded to the court of appeal with instructions
Rationale: The issue at hand is whether a battery, which is a harmful or offensive contact with a person, resulting from an act intended to cause the plaintiff to suffer such a contact, was committed. The intention need not be malicious or intended to inflict actual damage. The defendant's liability for the resulting harm of the action extends to consequences which the defendant did not intend, and could not reasonably have been foreseen, upon the basis that it is better for the intentional wrongdoer to suffer losses than for the innocent victim to suffer those same losses. The Supreme Court concluded that the plaintiff proved that a battery had been committed on him and that he is entitled to recover for all injuries resulting from the defendant's intentional tort. The fact that Bett did not intend to inflict actual damage does not render him immune from liability.
