Vance v. Vance

We granted certiorari in this case to consider two principal issues: (1) whether, under the “physical injury” test set forth in Bowman v. Williams, 164 Md. 397, 165 A. 182 (1933), damages were properly recovered by the plaintiff for emotional distress resulting from the defendant’s negligent misrepresentation and (2) whether under the principles of Harris v. Jones, 281 Md. 560, 380 A.2d 611 (1977), the plaintiff presented legally sufficient evidence to the jury to establish all elements of the independent tort of intentional infliction of emotional distress.

The relevant facts are these:…