Georgia-Pacific Corp. v. Carter
In Georgia-Pacific Corp. v. Carter, 62 Ark. App. 162, 969 S.W.2d 677 (1998), the Court held that if there is a causal connection between the primary injury and subsequent complication or disability, an activity of the claimant that triggers the subsequent complications must be "unreasonable under the circumstances," in order to be an independent intervening cause. Id.