Miller v. Willbanks

Shortly after Elizabeth Ann Miller (plaintiff) delivered a baby, Dr. David Willbanks (defendant) accused her of drug abuse based on the newborn's symptoms of drug-withdrawal syndrome, spreading his suspicions to hospital staff and Miller's own parents before ever confronting her directly; Miller agreed to a drug test that came back negative, but Willbanks continued spreading his accusation anyway and reported her to the local health department. Miller and her husband (plaintiffs) sued Willbanks and others (defendants) for intentional infliction of emotional distress, and the trial court granted the defendants summary judgment because the Millers had not presented expert evidence that Elizabeth Ann suffered serious mental injury from the defendants' conduct; the court of appeals affirmed, holding expert medical or scientific proof of serious mental injury was required for such a claim.