Roling v. Daily

HARRIS, Justice.

To date we have subscribed to the prevailing view that a tort recovery for emotional distress will be allowed only if accompanied by some physical injuries. It is also necessary, for such a recovery, to establish by expert medical testimony a causal connection between the defendant’s fault and the claimed emotional distress. A second causal connection is not however required between the plaintiffs physical injuries and the emotional distress. Because the trial court based its grant of judgment notwithstanding the verdict on the second requirement, we reverse and remand.

The…