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Camper v. Minor

Supreme Court of Tennessee, at Knoxville
915 S.W.2d 437 (1996)
ELI5:

Rule of Law:

A plaintiff may recover for negligent infliction of emotional distress, in the absence of a physical injury or physical manifestation, by proving the elements of general negligence. The emotional injury must be proven to be "serious" or "severe" and must be supported by expert medical or scientific proof.


Facts:

  • Bobby L. Camper was operating his cement truck on a four-lane highway in Kingsport, Tennessee.
  • At an intersection controlled by a stop sign, 16-year-old Jennifer L. Taylor, driving a car owned by Sharon Barnett, suddenly pulled out in front of Camper's truck.
  • The vehicles collided, resulting in the instant death of Taylor.
  • Camper did not sustain any substantial physical injury in the collision, only a minor scrape on his knee.
  • Moments after the accident, Camper exited his truck and witnessed Taylor's body in the wrecked vehicle from a close distance.
  • Camper subsequently suffered from post-traumatic stress disorder, including depression, loss of sleep, and crying outbursts, which he attributed solely to the experience of seeing Taylor's body.
  • Camper sought treatment from psychiatrists for his emotional injuries.

Procedural Posture:

  • Plaintiff Bobby L. Camper filed suit in a Tennessee trial court against Daniel B. Minor, the administrator of Taylor's estate, and Sharon Barnett, the car's owner.
  • The defendants filed a motion for summary judgment, arguing Camper could not recover for emotional distress because he suffered no physical injury and did not fear for his own safety.
  • The trial court denied the defendants' motion for summary judgment.
  • The defendants were granted an interlocutory appeal to the Tennessee Court of Appeals (an intermediate appellate court).
  • The Court of Appeals reversed the trial court's decision, granting summary judgment in favor of the defendants.
  • Camper was then granted permission to appeal to the Supreme Court of Tennessee, the state's highest court.

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Issue:

Does a plaintiff state a valid claim for negligent infliction of emotional distress when they suffer a serious emotional injury, supported by expert proof, as a result of a defendant's negligence, even without a contemporaneous physical injury or physical manifestation of the emotional harm?


Opinions:

Majority - Drowota, Justice

Yes. A plaintiff can recover for negligent infliction of emotional distress by satisfying the elements of general negligence, provided the emotional injury is serious and supported by expert proof. The court abandons the prior, rigid 'physical manifestation' rule, which required a plaintiff to show a physical injury or physical symptoms to recover for emotional harm. This old rule was deemed inflexible, arbitrary, and inconsistent, as evidenced by the numerous ad hoc exceptions courts had created over the years. The court adopts a general negligence approach, requiring the plaintiff to prove duty, breach of duty, injury or loss, causation in fact, and proximate cause. To prevent trivial or fraudulent claims, the court adds two requirements: first, the emotional injury must be 'serious' or 'severe,' defined as an injury with which a reasonable person, normally constituted, would be unable to adequately cope. Second, the existence of this serious emotional injury must be supported by expert medical or scientific proof. The court also held that the family purpose doctrine, which imposes vicarious liability on the owner of a vehicle for the negligence of a family member, survives the adoption of comparative fault because it is based on principles of agency, not joint and several liability among multiple negligent actors.



Analysis:

This decision significantly modernizes Tennessee's tort law regarding emotional distress by replacing the archaic 'physical manifestation' rule with a general negligence standard. By doing so, the court brings Tennessee in line with a growing number of jurisdictions that recognize that severe emotional trauma can be a standalone, compensable injury. The added requirements that the injury be 'serious' and supported by expert proof serve as crucial gatekeeping functions, balancing the goal of compensating genuine harm against the risk of frivolous litigation. This new framework shifts the legal inquiry from an arbitrary prerequisite of physical harm to a fact-based analysis of the severity and verifiability of the emotional injury itself.

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