Whitmire v. Woodbury

Smith, Judge.

This appeal is from a jury verdict awarding $63,598.01 damages to appellees in their action for trespass, assault, invasion of privacy and intentional infliction of emotional distress. We reverse.

1. Although appellants’ requested charge on proximate causation was incomplete and therefore properly rejected (see McMullen v. Vaughan, 138 Ga. App. 718, 721 (227 SE2d 440) (1976)), we nonetheless believe that the trial court committed reversible error by failing to give any charge on proximate causation.

Under Georgia law, a plaintiff may recover for severe emotional distress without…