Camper v. Minor
Supreme Court of Tennessee
915 S.W.2d 437 (Tenn. 1996)
Bobby Camper (plaintiff), driving a cement truck, was involved in a collision when 16-year-old Jennifer Taylor suddenly pulled out in front of him and was killed instantly; Camper viewed her body at close range afterward and suffered sleep loss, crying outbursts, depression, and other symptoms requiring psychiatric care. Camper sued Taylor's estate administrator and the car's owner (defendants) for negligent infliction of emotional distress; the trial court denied summary judgment because Camper had suffered minor physical injuries in the collision itself, but the intermediate appellate court reversed and granted summary judgment, reasoning Camper only saw the body after any fear for his own safety had passed and lacked a close relationship with Taylor, and Camper appealed.
Whether a plaintiff may recover damages for serious or severe emotional injuries by satisfying the ordinary elements of general negligence, without needing to show a contemporaneous physical injury or physical manifestation of the emotional injury.