Judy Komlodi, as Guardian for Michelle Komlodi, an Incapacitated Person, Plaintiff-Respondent v. Anne Picciano…

Summary

The Supreme Court affirmed the Appellate Division’s judgment in part, vacated the no‑cause verdict and remanded for a new trial because the trial court improperly gave a Scafidi (pre‑existing condition) charge and failed to tailor its jury instructions, while affirming the superseding/intervening causation charge. The Court held that a Scafidi charge is limited to cases where negligence combines with a pre‑existing condition to cause harm and is inappropriate where the plaintiff’s own conduct is the proximate cause.