Falzone v. Busch

Falzone (plaintiff) sat in a parked car while her husband stood in a nearby field; Busch's (defendant) vehicle struck her husband and swerved toward Falzone, putting her in fear for her own safety, which caused her to become physically ill. Falzone and her husband sued for negligence, but the trial court granted summary judgment against Falzone's claim, applying the traditional rule that a plaintiff cannot recover for fright-induced illness without a physical impact.