Miller v. Willbanks
8 S.W.3d 607 (1999)
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Rule of Law:
Expert medical or scientific proof is not generally required to establish the 'serious mental injury' element of a claim for intentional infliction of emotional distress. The outrageousness of the defendant's conduct provides sufficient corroboration to allow a jury to determine the existence of a serious mental injury based on lay testimony and other evidence.
Facts:
- Elizabeth Ann Miller gave birth to her daughter, Heather, at Morristown-Hamblen Hospital.
- The next day, Dr. David Willbanks diagnosed the newborn Heather with Drug Withdrawal Syndrome (DWS) without performing any drug tests.
- Dr. Willbanks accused Mrs. Miller of lying about her drug use during pregnancy and insisted on treating Heather for DWS.
- Rumors that Heather was a 'drug baby' spread throughout the hospital, leading hospital staff to treat the Millers rudely.
- Drug tests administered to both Mrs. Miller and Heather came back negative.
- Despite the negative tests, Dr. Willbanks continued the DWS treatment and reported his suspicions of Mrs. Miller's drug use to the Grainger County Health Department.
- A social worker and nurse from the Health Department subsequently visited the Millers' home to interview them and inspect their living arrangements over their objections.
Procedural Posture:
- The Millers sued Dr. Willbanks, Hamblen Pediatric Associates, and the Morristown-Hamblen Hospital Association in a Tennessee trial court for intentional infliction of emotional distress.
- The defendants filed a motion for summary judgment.
- The trial court granted the defendants' motion, dismissing the case because the Millers lacked expert proof of their serious mental injury.
- The Millers, as appellants, appealed the dismissal to the Tennessee Court of Appeals.
- The Court of Appeals affirmed the trial court's judgment.
- The Millers, as appellants, were granted an appeal to the Supreme Court of Tennessee.
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Issue:
Does a plaintiff need to present expert medical or scientific proof to support the 'serious mental injury' element of a claim for intentional infliction of emotional distress?
Opinions:
Majority - Barker, J.
No. Expert medical or scientific proof is generally not required to support the serious mental injury element of an intentional infliction of emotional distress claim. The court adopts the majority rule from other jurisdictions, distinguishing this tort from negligent infliction of emotional distress (NIED). For NIED, expert proof serves as a necessary safeguard against fraudulent claims. For IIED, however, the required element of 'extreme and outrageous conduct' itself serves as the safeguard, providing inherent credibility that the plaintiff suffered a serious injury. The court reasoned that jurors are capable of evaluating common emotional responses like grief, shame, and humiliation from lay testimony, physical manifestations, and descriptions of the intensity and duration of the distress, without needing an expert to explain them.
Analysis:
This decision aligns Tennessee with the majority of jurisdictions on the evidentiary requirements for IIED. It clarifies the distinction between proving injury in intentional versus negligent infliction of emotional distress cases, tying the need for expert testimony to the nature of the defendant's conduct. By lowering the evidentiary bar for surviving summary judgment, the ruling makes it easier for plaintiffs with legitimate IIED claims to reach a jury. The 'outrageous conduct' element remains the primary gatekeeper for such claims, ensuring that only the most egregious cases proceed.
