Womack v. Eldridge

Eldridge (defendant), posing falsely as a reporter, tricked Womack (plaintiff) into letting her photograph him, then gave the photo to an attorney defending a client accused of child molestation, who showed it to the victims — even though they said the man in the photo wasn't their attacker. Eldridge's subsequent testimony revealing Womack's name led to Womack being repeatedly questioned by police, summoned before a grand jury, and called to testify at multiple trial dates in a case he had no connection to. Womack sued for emotional distress, and a jury found for him, but the trial court set aside the verdict, holding emotional distress required accompanying physical injury.

Whether a plaintiff may recover for emotional distress that does not result in physical injury, which is intentionally or recklessly caused by the defendant's extreme and outrageous conduct.