Strickland v. Hodges

Clark, Judge.

Is there an independent right of action available to parents who are not present at an incident in which serious injuries are inflicted upon their child by the wilful and wanton negligence of a defendant so as to allow recovery for emotional distress and mental suffering which results from the parents learning of such injuries and seeing the injured child following the incident?

That question of first impression confronts us in this appeal by the parents from the grant of defendant’s motion for partial summary judgment. This ruling struck from a three-count complaint those two…