Beynon v. Montgomery Cablevision Ltd. Partnership

BELL, Chief Judge.

Whether “pre-impact fright,” or any other form of mental and emotional disturbance or distress, suffered by an accident victim who dies instantly upon impact is a legally compensable element of damages in a survival action is an issue hitherto unaddressed by this Court, but presented in this case. In Maryland, it is well-settled that, in the absence of a physical impact or injury directly resulting in harm, mental and emotional injuries such as fright are not compensable unless there are objective manifestations of such injury. See *464Green v. Shoemaker, 111 Md. 69, 77-78, 73…