Daley v. LaCroix
Michigan Supreme Court
179 N.W.2d 390 (Mich. 1970)
Relevant factsFree
LaCroix's (defendant) car went off the road and struck a utility pole near the Daleys' home, causing an electrical explosion that produced no direct physical impact on the Daleys but allegedly caused physical symptoms including traumatic neurosis and nervous upset; the trial court granted LaCroix a directed verdict on the emotional-distress claim, and the court of appeals affirmed.
IssueFree
Whether a plaintiff may recover damages for negligent infliction of emotional distress even if no physical impact occurred at the time of the negligence.