Quill et al. v. Trans World Airlines, Inc.

Court of Appeals of Minnesota
361 N.W.2d 438 (1985)

ELI5:

Rule of Law:

A plaintiff within the zone of physical danger may recover for negligent infliction of emotional distress where the claim's genuineness is guaranteed by the terrifying nature of the defendant's negligent act, and the distress is accompanied by definite physical symptoms, even if those symptoms do not require medical treatment.

Facts:

On April 4, 1979, Dean Abrahamson was a passenger on TWA flight 841, which was cruising at 89,000 feet.
The aircraft suddenly rolled over and plunged into a 40-second, near-supersonic tailspin, subjecting passengers to intense G-forces of approximately 6 Gs.
Abrahamson believed he was certain to die and was physically pinned to his seat by the G-forces.
The pilots regained control only 5,000 feet from the ground, approximately five seconds before impact.
For the next forty minutes, the damaged plane flew to an emergency landing in Detroit, with the crew offering no assurances of safety.
Since the incident, Abrahamson experiences anxiety on subsequent flights, manifesting in physical symptoms such as adrenaline surges, sweaty hands, and elevated pulse and blood pressure.
Abrahamson, a medical doctor, has not sought medical or psychiatric treatment for these symptoms, believing they could do nothing for him.

Procedural Posture:

Dean Abrahamson sued TWA and The Boeing Company in a Minnesota state trial court for damages.
After a trial on liability, a jury found TWA 70% causally negligent and The Boeing Company 30% causally negligent.
The Boeing Company settled with Abrahamson and was dismissed from the case.
Abrahamson's claim for damages proceeded to a separate jury trial solely against TWA.
The jury awarded Abrahamson $50,000 in damages.
TWA, the defendant, moved the trial court for judgment notwithstanding the verdict or, alternatively, for a new trial.
The trial court denied TWA's motions and entered judgment for Abrahamson.
TWA, as appellant, appealed the trial court's judgment to the Minnesota Court of Appeals, an intermediate appellate court.

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Issue:

Does a plaintiff state a prima facie case for negligent infliction of emotional distress under the 'zone of danger' rule when his emotional distress from a life-threatening airplane dive manifests in physical symptoms like adrenaline surges, sweaty hands, and elevated blood pressure, but does not require medical treatment?

Opinions:

Majority - Leslie, Judge

Yes. A plaintiff states a prima facie case for negligent infliction of emotional distress under these circumstances. Minnesota's 'zone of danger' rule allows recovery for emotional distress without contemporaneous physical injury, but requires that the distress manifest in physical symptoms. The court refused to import the higher 'severe emotional distress' standard from the separate tort of intentional infliction of emotional distress, reasoning that the zone of danger rule itself provides an indicia of genuineness. Although Abrahamson’s symptoms (sweaty hands, elevated blood pressure) were less severe than those in prior cases and did not require medical care, the court found them sufficient. The decision emphasized that the uniquely terrifying nature of the 40-second dive toward earth served as an independent guarantee of the claim's authenticity, thus lowering the required threshold for the severity of the physical manifestation.

Analysis:

This decision clarifies the 'physical manifestation' requirement for negligent infliction of emotional distress claims in Minnesota under the zone of danger rule. It establishes that the severity of the required physical symptoms can be evaluated in light of the severity and genuineness-guaranteeing nature of the defendant's negligent act. This lowers the evidentiary bar for plaintiffs who have undergone an objectively terrifying experience, allowing recovery for symptoms like adrenaline surges and elevated blood pressure, which might have been deemed insufficient in a less dramatic context. The case prevents a rigid application of the physical injury rule from barring legitimate claims where the emotional trauma is undeniable.

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