Shoulder Injuries in Georgia Accident Claims: Rotator Cuff and Beyond

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A shoulder that hurts after a Georgia crash raises one question first: did the collision cause the injury, or was it already there? MedlinePlus describes rotator cuff injuries that come from wear and tear and tears that happen suddenly from an injury, and it lists traffic accidents among the causes of shoulder dislocation. The diagnosis, the course of treatment, and the evidence about the shoulder before and after the crash carry the answer.

Why the Shoulder Is Easily Injured

MedlinePlus explains that the shoulder joint is made of three bones, the clavicle (collarbone), the scapula (shoulder blade), and the humerus (upper arm bone), and that the shoulders are “the most movable joints” in the body. They can also be unstable “because the ball of the upper arm is larger than the shoulder socket that holds it,” so the shoulder must be anchored by muscles, tendons, and ligaments. The shoulder problems it lists include sprains and strains, dislocations, separations, tendinitis, bursitis, torn rotator cuffs, frozen shoulder, fractures, and arthritis, and it states that providers diagnose shoulder problems through the medical history, a physical exam, and imaging tests.

Rotator Cuff Tears: Wear or Injury

The rotator cuff, MedlinePlus explains, is a group of muscles and tendons that holds the top of the upper arm bone in the shoulder socket and keeps the shoulder stable as the arm moves. It states that “[m]ost of them are wear-and-tear injuries from doing the same arm movements over and over,” but that tears “can happen over time or suddenly from an injury, such as falling on an outstretched arm or lifting something heavy.” A tear may go partway through a tendon (a partial tear) or all the way through (a full tear).

MedlinePlus lists people over age 40 as more likely to have a rotator cuff injury, stating that “[m]ost rotator cuff injuries are from the wear and tear of aging” and that “[b]y age 80, most adults have tears.” It also lists athletes in sports with repeated shoulder movements and people in jobs that require a lot of reaching overhead or heavy lifting, such as carpenters, construction workers, and painters.

Rotator cuff injuries “don’t always cause pain.” When they do, the pain can be felt at the top of the arm or shoulder and can be worse when lying on the injured shoulder, lifting or lowering the arm to the front or side, or reaching behind the back; a torn rotator cuff can also cause loss of strength in the arm and clicking or popping when the arm moves. A provider examines the shoulder, including its range of motion and where the pain is, tests arm and shoulder strength, and may order x-rays, an ultrasound, or an MRI. Treatment can include rest, ice, pain relievers, physical therapy, and a corticosteroid shot if other treatments do not help the pain.

Dislocation and Other Injuries

MedlinePlus describes a shoulder dislocation as an injury in which the ball at the top of the upper arm bone pops out of the cuplike socket in the shoulder blade, partly or completely. The causes it lists include sports injuries, “[a]ccidents, including traffic accidents,” and falls onto the shoulder or an outstretched arm. Symptoms include severe shoulder pain, swelling and bruising, numbness or weakness in the arm, neck, hand, or fingers, trouble moving the arm, an arm that seems out of place, and muscle spasms in the shoulder.

Treatment “usually involves three steps”: a closed reduction, in which the provider puts the ball back into the socket; a sling or other device worn for “a few days to several weeks”; and rehabilitation once pain and swelling improve. Surgery may be needed if the tissues or nerves around the shoulder are injured or dislocations repeat. MedlinePlus also lists separations and fractures among shoulder problems.

Proving What the Crash Did

Because MedlinePlus describes tears that develop over time and tears that happen suddenly from an injury, and states that rotator cuff injuries do not always cause pain, a shoulder claim turns on evidence of which occurred and when. Under Georgia’s damages statute, damage is too remote to recover when other and contingent circumstances outweigh the wrongful act in causing the injury (OCGA 51-12-8). An expert who addresses causation has to rest the opinion on sufficient facts or data and on reliable principles and methods (OCGA 24-7-702(b)), and may build it on facts other witnesses prove (OCGA 24-7-702(a)), such as testimony about how the shoulder worked before the crash and after it.

Evidence of an earlier condition can also support a jury charge on aggravation. In Setliff v. Littleton, 264 Ga. App. 711 (2003), a knee injury case in which the defense pointed to preexisting and degenerative problems, the Court of Appeals found no error in jury charges on aggravation and on an “egg shell plaintiff,” because a charge may be given on slight evidence and there was evidence to support both.

Frequently Asked Questions

When is surgery considered for a torn rotator cuff?
MedlinePlus states that a provider may suggest surgery if the tear is large or is from a recent injury, or if symptoms last for 6 to 12 months.

Can a dislocated shoulder dislocate again?
MedlinePlus states that a dislocation can make the shoulder unstable, that it then takes less force to dislocate it, and that this means a higher risk of it happening again.

Can household work the injured person can no longer do be part of the claim?
It can. Georgia’s list of economic damages includes the loss of services the injured person performed, unpaid domestic and other necessary services among them (OCGA 9-10-184(a)(1)).

  • MedlinePlus (National Library of Medicine), “Shoulder Injuries and Disorders” (last updated June 29, 2025); “Rotator Cuff Injuries” (last updated Jan. 8, 2024); “Dislocated Shoulder” (last updated May 1, 2019)
  • OCGA 51-12-8
  • OCGA 24-7-702(a), (b)
  • Setliff v. Littleton, 264 Ga. App. 711 (2003)
  • OCGA 9-10-184(a)(1)

Disclaimer

This article provides general information about shoulder injury claims under Georgia law. It is not medical advice or legal advice and does not create an attorney-client relationship. Whether a crash caused or worsened a shoulder injury depends on the medical evidence and the specific facts. A person with a shoulder injury after a crash should seek medical care and consult a licensed Georgia attorney promptly about the particular situation.

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