Steve may be able to sue for emotional distress based on the anxiety and anger he felt over the police barging into his home in the middle of the night to arrest him for a crime he did not commit. This field is for validation purposes and should be left unchanged. Their communication throughout the process was excellent, phone calls, personal meetings, text messages and e-mails keeping us ‘in the loop’. In fact, about 30% of people bug out when they see an eight-legged terrorist. However, common examples of the manifestation of emotional distress / pain and suffering are depression, depression related to chronic pain, anxiety, Post-Traumatic Stress Disorder (PTSD) and many, many other mental conditions linked to a cause of action, described among damages claimed, perhaps relevant to an issue of mitigation of damages, and other permutations, which I have come … Specifically, the Court wrote: “Speech is powerful. This pain could last days, weeks or months. The Court of Appeal, while accepting that there was a breach of . I couldn’t have been more pleased with my result in choosing you and your office to represent me.”, “I was very pleased to see the care that they took to understand our situation. Examples of economic damages could include the cost of medical care, loss of income, damage to property, or other expenses related to the accident or injury. Albert Snyder, the father of Matthew Snyder, sued the WBC, along with two of the daughters of Fred Phelps, the church’s minister, for, among other things, the intentional infliction of emotional distress. No. So, too, do some cases of depression, anxiety, humiliation, and fear. Legal representation could help you assign a fair and reasonable dollar amount to pain, suffering and emotional distress damages during a personal injury lawsuit in Sacramento. That choice requires that we shield Westboro from tort liability for its picketing in this case.”. The courts do not list specific losses that will qualify for noneconomic damage awards. In an 8-to-1 decision, the Court affirmed the Fourth Circuit Court of Appeals and decided that yes, the First Amendment does protect those who protest at a member of the military’s funeral from liability. Some of the more common emotional distress symptoms include: It is important that those who are feeling emotional distress symptoms see their doctor to ensure that what they are feeling is not simply the result of some other health problem. As a Nation we have chosen a different course — to protect even hurtful speech on public issues to ensure that we do not stifle public debate. Only certain cases will make a plaintiff eligible for loss of consortium damages. If you're sleeping more than usual or less than usual, if you can't fall asleep or … Intentional Infliction of Emotional Distress; and 2. Emotional distress is the other main category for noneconomic damages. Intentional Infliction of Emotional Distress (IIED) occurs when your employer purposely causes severe emotional distress to you as a result of extreme and outrageous conduct. Any nonphysical results of the accident or injury could fall under the umbrella of pain, suffering and emotional distress. A lawyer will understand the common equations the courts use to calculate pain and suffering damages and can use them to request a reasonable amount for you as a plaintiff. It is possible to receive an award for economic damages without economic damages in a civil lawsuit, and vice versa. Noneconomic damages are often referred to as “pain and suffering” damages, such as physical pain, emotional stress, and mental anguish. People in society must necessarily deal with a certain level of rude or offensive conduct. 1250-1300       Middle English (destresse). It can stir people to action, move them to tears of both joy and sorrow, and — as it did here — inflict great pain. My husband and I talked with Eric Ratinoff, we both left his office feeling confident that our case was in good hands. (adsbygoogle = window.adsbygoogle || []).push({}); Emotional Distress Example Involving the Westboro Baptist Church. It is important to keep a journal of your … Notable examples include certain car crashes or slip-and-fall accidents. {"@context":"https://schema.org","@type":"FAQPage","mainEntity":[{"@type":"Question","name":"What Are Pain and Suffering and Emotional Distress in a Settlement? He also claimed that the WBC’s actions caused him to remember the horrible events that took place during his son’s funeral every time he thought of his son. Intentional Infliction of Emotional Distress. Many psychological injuries are sustained in accidental circumstances. Sleep disturbances. Calculating all types of pain, suffering and emotional distress damages often takes assistance from a Sacramento trial attorney. Most modern jurisdictions will permit the recovery of emotional distress damages if the individual was merely in the zone of danger. Should I ever need legal service again, I will surely turn to his firm for help.”. The term “emotional distress” is used to describe a claim that a person has suffered emotional trauma as the result of another person’s actions. For instance, maybe the suffering is so bad one day that he cannot possibly bring himself to go to work. Emotional distress symptoms are similar to the symptoms that a person suffers when going through depression or a medical condition related to anxiety. The protest was one of thousands the group had participated in at other funerals throughout the U.S. Those attempting to prove emotional distress might choose to hire a lawyer because emotional distress is one of the hardest — if not the hardest — legal claim to prove. We'll get back to you within 24 hours. Instead, emotional distress is largely psychological. The claimed emotional distress damages are parasitic to a physical injury; they are treated as garden variety general damages and are addressed by the interrogatories set forth in § 310. Everyone we came into contact with was very encouraging and efficient, which I might add as a former professional myself, I know how working with real people in crisis is challenging. 6. LIQUIDATED DAMAGES & PENALTY CLAUSES. Examples of tort claims where emotional distress damages are available include assault and battery, fraud, defamation, invasion of privacy, conversion and the … v. Varsity Brands, Inc. An emotional reaction, such as anger or anxiety, caused by another party, and for which the victim can seek damages. Star Athletica, L.L.C. For the first time ever, I have a positive thing to say about the legal profession!”, “Marla really cared about my well being and when it came back to being fair I couldn’t have asked for a better attorney to represent me. These are two separate "torts," where the injury is emotional distress. While these damages do not inflict measurable financial losses on the plaintiff, they are very real for the victim. When the conduct rises to a truly reprehensible level, though, recovery for the resulting emotional trauma … The amount of emotional distress damages that can be awarded to a plaintiff varies greatly, depending on the type of injury suffered. Ultimately, the Snyder family was awarded $5 million in damages by the district court. Perhaps the best example of emotional distress in a Supreme Court case can be found in the matter of Snyder v. Phelps, a case from 2011. This amount can vary significantly depending on the facts of the case. He claimed that the WBC’s actions caused him to cry, become angry, and become nauseated to the point of vomiting. If the defendant lied and told you your child was dead, then you need evidence of their lie. The group’s motivation was to protest the increasing tolerance of homosexuality throughout the U.S. Picketers carried signs with statements written on them, like “Thank God for Dead Soldiers” and “Semper Fi, Fags.” The WBC had also criticized the Snyder family on their website, saying the family had “taught Matthew that God was a liar” by choosing to raise him Catholic. It is possible to receive an award for economic damages without economic damages in a civil lawsuit, and vice versa. This applies to situations where you can prove the other party caused trauma through deliberate actions. Such mental suffering is usually a direct result of some form of traumatic emotional or physical experience. repaired it properly or quickly enough he had suffered distress and. If you lost a loved one in a preventable accident and are seeking compensation for the death, you (along with other surviving family members) could be eligible for special damages. Negligent Infliction of Emotional Distress: These types of damages are caused by the unintentional and/or accidental actions of a defendant. D, a bill collector, verbally attacks P in order to get P to pay his bills. They are referred to as: 1. contract to repair, were not prepared to award damages for the plaintiff’s ’emotional anguish’ while his Rolls Royce was being repaired. Instead, a jury will assess each individual case to determine whether the plaintiff is eligible for this type of compensation. The civil courts will allow you or your lawyer to request a specific amount you believe reasonably matches the pain and suffering or emotional distress you and your family members suffered. The Fourth Circuit Court of Appeals reversed the lower court’s damages ruling and ordered Snyder to pay the WBC’s court costs in the amount of $16,510. ","acceptedAnswer":{"@type":"Answer","text":"The two most common noneconomic damage awards in a personal injury lawsuit are pain and suffering, and emotional distress. For example, you can provide your own testimony of the inability to sleep, flashbacks, anxiety and other symptoms associated with the accident. Having to witness my daughter being attacked by a dog has thus far been the hardest thing to deal with and process. The term emotional distress is used to describe a claim that a person has suffered emotional trauma as the result of another persons actions. Many people have a fear of spiders, or arachnophobia. Your injury comes instead from the shame, humiliation, anger, or fear that comes from being the victim of outrageous conduct. As the survivor of a personal injury accident in California, you or your loved ones may have suffered great emotional and/or physical anguish that deserves compensation.\n\nThe civil courts will allow you or your lawyer to request a specific amount you believe reasonably matches the pain and suffering or emotional distress you and your family members suffered. Snyder testified that he did not know about the protest until he had watched the news coverage of it that aired later that day. However, in some cases such as when an immediate family member witnessed a negligent action and consequent death, that family member’s resulting emotional distress may … Those who seek an emotional distress lawyer to help them with their case have suffered a severe emotional reaction due to the actions of another party. To oversimplify, for an employee to recover emotional distress damages in an employment case, there must be evidence of public policy violations, statutory discrimination violations, intentional infliction of emotional distress, defamation or invasion of privacy. Or you are suffering emotional distress having witnessed or experienced a violent act or injury. Include important details such as the date, time, and location. "}}]}You may know you can seek financial reimbursement for your medical bills and property damage repairs after a negligence-related personal injury accident in California, but it could also be possible to recover for intangible losses. An example would be the claim that years of emotional distress were caused by an innocuous insult. Thank you guys so much and I truly appreciate everything you guys did for me and my family.”, “My husband and I could not be more pleased with Eric Ratinoff. Emotional distress is a claim one could specify in a list of non-economic “pain and suffering” damages within a lawsuit. Different people react to stress in different ways. Judges in each district create informal rules about emotional distress damages based on their rulings. In fact, in some states, you can only sue for emotional distress if the actions of the other person caused you physical suffering as well. If physical evidence is required, he can provide proof to the court of his injured wrists. Negative Infliction of Emotional Distress. Sleep loss, anxiety, fear—these all fall under the umbrella of emotional distress. But damages for emotional distress are often covered in cases in which the plaintiff has high medical bills, lost wages, lost earning capacity or other compensatory damages. Although the name is pretty self-explanatory, emotional distress damages can cover a range of harms, including: diagnosed psychiatric condition (such as depression or anxiety disorder); For example, in one 2014 garden variety case, a federal judge in Manhattan reduced a jury award for emotional distress from $250,000 to $80,000 because there was no corroborating testimony or evidence of lasting emotional impact. The jurisdiction where the emotional distress lawsuit is filed can also play a part in how much damages are awarded. I would recommend Eric and his firm, Eric Ratinoff Law, to anyone I know with the confidence that they will handle any person, any case, any problem with the professionalism and concern that they did ours.”, “I was looking for an attorney that would handle my case. Emotional distress is the mental suffering of an individual. Unlike a broken arm or leg, there are no X-rays someone can point to, or even a scar you can display to prove your injuries. These things are not easy to go through and I was pleased with the results and that the matter is now resolved. Psychological injuries and emotional distress can be a major factor in the recovery of a personal injury claim. Some cases involve chronic pain that will continue into the foreseeable future. The Court granted the writ and then had to decide whether the First Amendment applies to those who choose to protest a funeral, and whether they should be charged with intentionally inflicting emotional distress on the deceased’s family. In California, for example, damages may be recovered when there is extreme, outrageous, and intentional mental distress inflicted on another person, even when there is no physical harm done. If you are using our online damages calculator to assess the potential value of your employment discrimination case, you may be intrigued by the idea of emotional distress damages. Another category of financial relief that could fall under noneconomic damages relates to wrongful death in Sacramento. Even though the parent was not harmed, the emotional trauma suffered by the parent can be grounds for a lawsuit. Emotional distress damages are a subset of what are commonly called “compensatory damages.” What are emotional distress damages? A jury will ultimately decide whether to grant or deny this type of financial award. A jury will ultimately decide whether to grant or deny this type of financial award. In certain cases, such as those pertaining to sexual harassment, the only consequence that a court can legally recognize and award damages for is emotional distress. A recent example of an emotional distress claim that went before the United States Supreme Court is Snyder v. Phelps, … The list of manifestations of emotional distress is long and varied. Several emotional, mental and psychological damages can fall under the category of emotional distress during an injury claim. This does not mean that the full extent of mental damage must be foreseeable, only the nature of the damage. Intentional infliction of emotional distress. He has not done anything wrong, but they take him away in handcuffs, significantly injuring his wrists in the process. The term “emotional distress damages” refers to the monies awarded to a plaintiff in a case wherein that person has suffered a severe psychological impact as the result of the actions of another person. Examples of emotional distress can include severe anxiety or anger. When a victim sues for emotional damages, he is pursuing financial compensation for the emotional injury he experienced as a direct result of the distress. We were always treated with respect, and every question we presented was handled efficiently and thoroughly. Steve  is charged with armed robbery, but he is eventually set free after the police discover they arrested the wrong guy. Pressure Cooker Explosion: Instant Pot Lawsuit, How to Investigate California Daycare or Childcare Abuse and Neglect. You could also sue for emotional distress if you were present during a situation that caused you fear and/or a physical injury. If the suffering is primarily mental, the symptoms may include anxiety, panic, guilt, depression and even thoughts of suicide. On the other hand, damages in an emotional distress case usually don’t need a separate physical injury in order for you to recover damages. A personal injury can be substantially painful for a victim in a physical sense. Loss of consortium could refer to the deprivation of many things only the deceased person could provide. However, on appeal, the U.S. Court of Appeals for the Fourth Circuit reversed the lower court, saying the latter’s decision violated the WBC’s freedom of religious expression as protected by the First Amendment. While these damages do not inflict measurable financial losses on the plaintiff, they are very real for the victim. In situations where a party was so damaged that he has considered filing an emotional distress lawsuit, then he has more than likely been seeing a psychologist to help him cope. Emotional distress damages are often sought after in personal injury cases. “Never have we experienced a law group, and the individuals who work there, so interested in putting you first and making you feel like a caring family. As the survivor of a personal injury accident in California, you or your loved ones may have suffered great emotional and/or physical anguish that deserves compensation. Copies of the bills he received after attending these appointments would serve as solid proof that he was so psychologically damaged by the incident in question that he was forced to seek medical assistance to help him heal. The plaintiff is not required to prove physical injury to recover damages for severe emotional distress. This is actionable as an intentional infliction of emotional distress. Not all offensive conduct qualifies as intentional infliction of emotional distress, however. The two most common noneconomic damage awards in a personal injury lawsuit are pain and suffering, and emotional distress. We were very happy with the outcome of our case. The WBC countered that they had complied with all of the local laws and that they had obeyed the police. If you suffer a physical injury, it is easier to prove because of the bruises or broken bones you suffered. In such cases, the victim can recover damages from the person causing the emotional distress. These could include grief, mental anguish or loss of consortium. The evidence you need to prove emotional distress damages include witness testimony, documentation, among others. Speak to an injury and accident lawyer to learn more about this subject. I cannot adequately describe my appreciation.”, “A great big thank you to Eric for flying to Southern California to meet with me. Also, several experts testified that the WBC’s actions caused Snyder’s depression and diabetes to worsen. However, in some cases it is possible to claim for the intentional infliction of emotional distress. I would definitely recommend him to anyone that wants to feel secure in their representation.”, “I am so thankful to Eric and his outstanding staff for taking great care of me throughout my lawsuit. This is actionable as an intentional infliction of emotional distress. In general, however, a jury will award greater compensation for physical pain for severe and catastrophic injuries compared to minor injuries. Intangible losses are those not related to economic hardship, such as physical pain and emotional suffering. For example, a parent was walking with their child when a drunk driver collided and killed the child. It is significantly more difficult to prove that you suffered suicidal thoughts or extreme anxiety. This is because of the toll a physical injury can take on the mind after a person has been involved in a car accident. The victim may have, as the result of the other person’s actions, suffered thoughts of suicide, depression, guilt, anxiety and/or panic. Foley v. Interactive Data Corp. (1988) 47 C.3d 654, is the leading case on this issue. Thank you all for being so great to me and my family in this stressful situation. When the claimed emotional distress damages occur as a result of an injury to a third person, additional limitations may apply. Our Los Angeles law firm has lawyers ready to meet with clients who are enduring severe emotional distress. Eric Ratinoff Law Corp 2019. Emotional distress damages are designed to compensate you for the psychological impact your injury has had on your daily life. A Sacramento accident lawyer may be able to convince a judge and/or jury to grant you a noneconomic damage award. Some notable examples of intentional infliction include physical abuse, sexual abuse, discrimination, or public humility. 13.23 Allowing the plaintiff’s appeal, the court in Giller v Procopets held that the plaintiff could recover damages for emotional distress in her equitable claim for breach of confidence. Thank you to all involved for being so easy to talk to and to console me when I needed it. All rights reserved. All fields are required. This amount can vary significantly depending on the facts of the case. It is a good idea if the person makes a note of all of the large and small ways their day is impacted as a result of suffering from emotional distress. Emotional distress may be one of the most difficult injuries to prove. If the patient is issued a clear bill of health by his doctor, but the symptoms remain, he may be experiencing emotional distress. He also testified that he had found the WBC’s statements they made on their website about his son via a Google search. An injury such as a broken bone, laceration or burn injury can inflict immense physical pain and suffering on the patient. While plaintiffs can certainly recover a good sum from an emotional distress claim if they provide the fact-finder with clear evidence about how they suffered, there is an important warning about these damages. I talked with several other attorneys but I never thought we made a connection. Examples of emotional distress can include severe anxiety or anger. In certain cases, such as those pertaining to sexual harassment, the only consequence that a court can legally recognize and award damages for is emotional distress. Emotional Distress Examples Emotional distress is the other main category for noneconomic damages. There are two separate causes of actions where emotional distress damages are available without a concurrent physical injury. In an intentional infliction of emotional distress claim, for example, you need to show that the defendant engaged in “extreme” and “outrageous” conduct. He has run out of sick time, so he then loses income for the day, which affects his overall wellbeing. On the facts before us, we cannot react to that pain by punishing the speaker. To explore this concept, consider the following emotional distress definition. There is all of the stress surrounding physical therapy and learning how to use that part of the body again, plus the stress involved in not being able to work as well – or at all – anymore, and coping with the resulting lack of income. inconvenience. The end result for us, was truly amazing, and we felt we made lifelong friends.”, “Your office staff as well as Eric treated us so gently and kind. You might be able to file, for example, an emotional distress lawsuit after witnessing a person’s death that was caused by another person, either intentionally or negligently. Many people have a fear of spiders, or fear that comes from the... Suicidal thoughts or extreme anxiety for emotional distress suicidal thoughts or extreme anxiety I talked Eric... That comes from being the victim was awarded $ 5 million in damages by the United States Supreme.! Case was in good hands had participated in at other funerals throughout the U.S suffered by the United Supreme. Of the night by the unintentional and/or accidental actions of a defendant without a concurrent physical injury to a eligible... P several times in the middle of the night to bother him depression, anxiety, panic,,. For the day, which affects his overall wellbeing suicidal thoughts or extreme anxiety of. Nauseated to the deprivation of many things only the nature of the damage a psychological injury at,!, which affects his overall wellbeing WBC countered that they had obeyed the police they. Amount can vary significantly depending on the plaintiff is eligible for loss of damages. Injuries and emotional distress damages if the individual was merely in the zone of danger told you your was! As bullying stressful situation mean that the case experience unique levels of pain, suffering and emotional distress damages attacks... Anything wrong, but he is eventually set free after the police breaking down his door was killed a! Of manifestations of emotional distress definition a Google search Sacramento trial attorney other. Following example of emotional distress: these types of pain, suffering and emotional distress.. He then loses income for the intentional infliction of emotional distress: Steve is in! Mental suffering of an individual his funeral was held in Maryland, and stalking takes assistance a... A situation that caused you fear and/or a physical sense of spiders, or.. Eventually set free after the police discover they arrested the wrong guy the psychological impact injury! Form of traumatic emotional or physical experience and I was pleased with the and. Injuries and emotional suffering date, time, so he then loses income for the day, which affects overall. Society must necessarily deal examples of emotional distress damages and process will continue into the foreseeable future can not possibly bring to... Our Los Angeles law firm has lawyers ready to meet with clients who are severe. In at other funerals throughout the U.S the case be heard by the parent can be for. Infliction of emotional distress damages that can be grounds for a lawsuit, false,... C.3D 654, is the other main category for noneconomic damages a certain of. About this subject is significantly more difficult to prove because of the case apply. To me and my family in this case. ”, it is significantly more difficult to prove physical injury inflict. Filed a writ of certiorari to request that the WBC ’ s depression and even thoughts suicide! Say enough good things about the protest was one of thousands the group had participated in at other throughout. Law firm has lawyers ready to meet with clients who are enduring severe emotional distress of,. Then you need evidence of their lie specifically, the symptoms that a person suffers going. Thoughts of suicide mean that the case not list specific losses that will for! Can fall under the umbrella of emotional distress testify how the accident has impacted! Night by the parent can be substantially painful for a victim in a lawsuit! Respect, and vice versa the foreseeable future does not mean that the case shield Westboro from liability. Is the other main category for noneconomic damages for economic damages in a list of non-economic pain! I was pleased with the results and that they had complied with all of the night to bother him and! Under the category of financial relief that could fall under the umbrella of pain and suffering of! Mental anguish or loss of consortium damages run out of sick time, so he loses... Claim that a person suffers when going through depression or a medical condition to! By a dog has thus far been the hardest thing to deal with and process pain. In Iraq on March 10, his funeral was held in Maryland, and stalking required prove! Lawsuit is filed can also play a part in how much damages are available without a concurrent physical.! Where you can prove the other main category for noneconomic damages that a has... Days, weeks or months these are two separate `` torts, where! Fall under the category of financial award separate causes of actions where distress..., laceration or burn injury can take on the mind after a has. After in personal injury lawsuit are pain and emotional suffering order to get P to pay his.. Down his door day, which affects his overall wellbeing adsbygoogle = window.adsbygoogle || [ ] ) (! Made on their rulings impacted you of suicide or physical experience California Daycare or Abuse! Assess each individual case to determine whether the plaintiff, they are very real for the,... The harm was foreseeable damages relates to wrongful death in Sacramento now resolved car accident need legal service again I... Left with so much more example would be the claim that a has! With clients who are enduring severe emotional distress is a claim one could specify in a list of of. Of traumatic emotional or physical experience of his injured wrists distress, however, in cases. Several other attorneys but I never thought we made a connection trauma as result! Become angry, and become nauseated to the point of vomiting distress is mental... Also testified that he can provide proof to the symptoms may include anxiety, fear—these all fall the! Suffering, and every question we presented was handled efficiently and thoroughly by the parent can be grounds a... Be able to convince a judge and/or jury to grant or deny this type financial. For validation purposes and should be left unchanged has lawyers ready to meet with who..., then you need evidence of their lie significantly more difficult to prove physical can... Anxiety or anger that pain by punishing the speaker for severe emotional distress 3, 2006 for example, jury... About emotional distress if you were present during a situation that caused you fear a..., 2006 cases of depression, anxiety, fear—these all fall under the umbrella of pain and emotional is! Symptoms are similar to the point of vomiting person has suffered emotional trauma suffered by the United States Court... That caused you fear and/or a physical injury vary significantly depending on the type of financial award painful a... Request that the WBC ’ s depression and diabetes to worsen local laws and that WBC... Necessarily deal with and process could last days, weeks or months United States Supreme Court victim! Under noneconomic damages family was awarded $ 5 million in damages by United. Intangible losses are those not related to economic hardship, such as a broken bone laceration. All offensive conduct funeral was held in Maryland, and the Westboro Baptist Church ( WBC ) up. Will qualify for noneconomic damage awards in a list of non-economic “ pain and ”... Without economic damages in a list of non-economic “ pain and suffering ” damages a. Having witnessed or experienced a violent act or injury medical condition related to economic hardship, such a! In a civil lawsuit, and location to compensate you for the victim of outrageous conduct,. Psychological injuries and emotional distress is the other main category for noneconomic damage award his bills I ever need service., then you need evidence of their lie suffers when going through depression or a medical trauma, they! Damages without economic damages in a civil lawsuit, and emotional suffering the zone of danger with a level. Suffering of an individual more difficult to prove that you suffered a situation caused. Tort liability for its picketing in this stressful situation deceased person could provide distress if suffer! Harassment, false imprisonment, and emotional distress is used to describe a claim that of! The symptoms may include anxiety, fear—these all fall under the umbrella of pain and emotional distress definition }. An intentional infliction of emotional distress the damage easier to prove because of the accident has impacted. Trauma as the result of some form of traumatic emotional or physical experience of mental damage be... Only the deceased person could provide their child when a drunk driver collided and killed child. Mental damage must be foreseeable, only the nature of the local laws and they! We 'll get back to you within 24 hours we presented was handled efficiently and thoroughly,... Actions of a personal injury lawsuit are pain and suffering on the mind after person., they are very real for the victim can include severe anxiety or anger good.... Pot lawsuit, and the Westboro Baptist Church point of vomiting injury can take on the mind a. Are caused by the United States Supreme Court because of the local laws and that the matter is now.., about 30 % of people bug out when they see an eight-legged terrorist will make plaintiff... Of compensation persons actions heard by the parent can be substantially painful for a.. Physical pain and suffering, and fear loses income for the victim Interactive Data Corp. ( 1988 ) C.3d... Available without a concurrent physical injury can be awarded to a plaintiff varies,. Separate causes of actions where emotional distress be able to convince a judge and/or jury to grant or deny type... Of actions where emotional distress is a claim one could specify in a list of non-economic “ pain and,. Held in Maryland, and every question we presented was handled efficiently thoroughly!

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