Spade v. Lynn & Boston Railroad
47 N.E. 88, 168 Mass. 285, 38 L.R.A. 512 (1897)
Rule of Law:
There can be no recovery for physical injuries caused solely by fright or mental disturbance arising from unintentional negligence, unless there is an immediate physical impact or injury to the person from an external source.
Facts:
- Mary A. Spade was a passenger on a Lynn & Boston Railroad Company streetcar.
- A conductor employed by the Lynn & Boston Railroad Company forcibly ejected a drunken man from the streetcar.
- In the process of ejecting the man, the conductor violently pushed him against another passenger.
- Mary A. Spade, witnessing this incident, became greatly frightened and suffered a severe nervous shock.
- As a result of the fright and nervous shock, Mary A. Spade developed a chronic disease.
Procedural Posture:
- Mary A. Spade sued the Lynn & Boston Railroad Company in a trial court for damages.
- The trial court instructed the jury that if fright or nervous shock produced a bodily injury, there could be a recovery for that bodily injury.
- The jury returned a verdict in favor of Mary A. Spade.
- The Lynn & Boston Railroad Company filed exceptions to the trial court's jury instructions, appealing to the Supreme Judicial Court of Massachusetts.
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Issue:
Does a person who suffers bodily injury caused solely by fright or mental disturbance, resulting from another's unintentional negligence, have a claim for damages when there is no physical impact or external injury to the person?
Opinions:
Majority - Allen, J.
No, a person cannot recover for physical injuries caused solely by fright or mental disturbance resulting from unintentional negligence, where there is no physical impact or external injury to the person from without. The court acknowledged that fright and mental distress can cause real suffering and even physical effects, noting that 'a physical injury may be directly traceable to fright.' However, the court's reasoning for denying recovery rests on the practical administration of the law. It determined that it is 'impossible satisfactorily to administer any other rule' because allowing such claims would 'open a wide door for unjust claims, which could not successfully be met.' The court stated that 'it is unreasonable to hold persons who are merely negligent bound to anticipate and guard against fright and the consequences of fright,' as individuals vary widely in their sensitivity. The general rule limiting damages to 'natural and probable consequences' applies, and this rule aims to balance the just rights of both parties by requiring compensation only for results usually found to exist in persons of ordinary physical and mental strength. This decision does not extend to cases where there is an intention to cause mental distress, gross carelessness, or recklessness.
Analysis:
This case establishes the 'physical impact rule' in Massachusetts for claims of negligence resulting in emotional distress and subsequent physical injury. It highlights the judiciary's concern with the practical challenges of administering claims for purely emotional harm, particularly the potential for fraudulent claims and the difficulty of drawing clear lines of proximate causation. While this strict rule was a prevailing view in many jurisdictions at the time, it has been widely criticized and subsequently eroded or rejected in many jurisdictions, including Massachusetts, which later adopted more permissive standards like the 'zone of danger' or negligent infliction of emotional distress tests. The case underscores a historical judicial reluctance to compensate for non-tangible injuries without a clear external marker.
