Brief Fact Summary.
A women’s car was hit by a train, causing her emotional turmoil.
Synopsis of Rule of Law.
If negligence caused fright, which caused other adverse consequences, then the negligence is the proximate cause of the consequences.
The Court held: Where negligence proximately caused fright, in one within the immediate area of physical danger from that negligence, which in turn produced physical consequences such as would be elements of damage if a bodily injury had been suffered, the injured party is entitled to recover under an application of the prevailing principles of law as to negligence and proximate causation.View Full Point of Law
The defendant maintained a railroad crossing. The plaintiff went to use the crossing, and her car was stalled, because the defendant had negligently allowed a rut to form, which caught her wheels, stranding her on the railroad tracks. A train soon came, and unable to free her car, she bailed out at the last second, and escaped without physical injury. Plaintiff brought suit for adverse effects in her life allegedly stemming from the fright she suffered.
Was the defendants negligence the proximate cause of the plaintiffs injuries?
Yes, the negligence was the proximate cause of the injuries.
The court finds in favor of the plaintiff. They reason that the defendant’s liability for their negligence is not confined to the physical results of the action (here the destruction of the car), but rather that the proximate cause extends to all the injuries suffered because of the negligence, whether or not physical. The court noted that while the fright suffered was not itself a cause of action, the adverse consequences suffered as a result of the fright were.