Mitchell v. Rochester Railway

While Mitchell (plaintiff) stood at a Rochester street crosswalk waiting to board a horse-drawn car, another horse-drawn car owned by Rochester Railway (Railway) (defendant) came rushing toward her (in one telling of the case, coming to a stop only after placing her between the heads of the two lead horses), and though it never actually struck her, the extreme fright caused her to faint, lose consciousness, and later suffer a miscarriage and illness. Medical testimony at trial suggested the shock of the event was sufficient to have caused the miscarriage, and the lower courts entered judgment for Mitchell on her negligence claim; Railway appealed.