negligent infliction of emotional distress nevadanegligent infliction of emotional distress nevada

WebOn January 11, 1980, Ron and Chrystal Eaton and their thirteen-month-old daughter, Amber, were traveling west on Interstate 80 between Battle Mountain and Winnemucca, Nevada. As the Supreme Court of New Jersey noted: Portee v. Jaffee, 417 A.2d at 526. If she does so, Chrystal may be awarded additional damages based upon the jury's evaluation of this portion of her emotional trauma. Prosser and Keeton, The Law of Torts, 54, p. 363 (5th ed. a legal cause of action in Nevada that is generally brought by someone who witnesses a See D'Amicol v. Alvarez Shipping Co., Inc., 31 Conn. Supp. II Harper and James, The Law of Torts 18.4, p. 1031 (1956). 555, 380 N.E.2d 1295; Toms v. McConnell, 45 Mich. App. In the context of bystander recovery, if the victim's negligence exceeds that of the defendant, then the victim cannot recover for his or her injuries and neither can the witness recover for the emotional distress caused by observing those injuries. The State's pretrial motion in limine to exclude such evidence was denied. Foreseeability is a requirement in all standard negligence cases: in essence, a defendant must have been able to reasonably predict that his or her actions could result in the negative consequences experienced by the plaintiff. Under this reasoning, it is not the precise position of plaintiff or what the plaintiff saw that must be examined. Chrystal does not dispute that the $29,000 was in exchange for a release of all claims, including both her personal injury and her wrongful death claims, against the settling defendants. See, e.g., Blue v. Renassance Alliance., Superior Court, judicial district of New Haven at Meriden, Docket No. The impact dislocated Chrystal's ankle. Ron tried to change lanes again and to slow down. We look forward to serving you. WebThe Concept of NIED in Georgia. WebThe damages awarded in negligent infliction of emotional distress claims differ depending on the state. keys to navigate, use enter to select, Stay up-to-date with how the law affects your life. The Court in this case ruled in favor of a plaintiff who suffered emotional distress from witnessing a relative's death; in a persuasive context, it has been cited numerous times in other states' courts since. shock or trauma) from the negligence of another. 211, 457 N.E.2d 1; Whetham v. Bismarck Hospital, 197 N.W.2d 678. At 6:34 p.m., Trooper Butler asked the dispatcher whether the sanding trucks were coming out because he had received several reports from truckers of ice on Golconda. The State argues that the placement of warning flares is a discretionary act. Sep 2022. Emotional distress is mental or emotional harm (such as fright or anxiety) that is not directly brought about by a bodily injury but manifests itself in related physical symptoms. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Please enter a legal issue and/or a location, Begin typing to search, use arrow The distress must either result from a physical injury or be so egregious that it results in physical symptoms. Your lawyer can use this to your advantage to recover compensation for both physical and mental anguish. [7] Fears that the Dillon "foreseeability test" would lead to unlimited liability have proven to be unfounded. The difference between a bystander case and a typical NIED case is that the plaintiff in a bystander case experienced mental or emotional anguish as a result of seeing a close family member suffer grave injury, as opposed to being the direct victim of the defendant's negligent act. See also Stadler v. Cross, 295 N.W.2d 552, 554 (Minn. 1980). When she asked the patrolman about her baby, he just shook his head. Rickey v. Chicago Transit Auth., 98 Ill. 2d 546, 75 Ill.Dec. At 7:10 p.m., the Eatons' car headed down the western slope of Golconda at about fifty miles per hour. Search, Browse Law After proceeding to trial against the State, the plaintiff may obtain a $1 million judgment. We therefore reject the zone of danger rule as unnecessary to delineate liability under this cause of action. CV-05-4001949-S (May 12, 2006, Shluger, J.) We reject appellant's assignments of error and affirm the judgment for Chrystal. 29 A.L.R.3d 1337, 1356. Because an NIED claim could potentially turn into a claim simply for "hurt feelings," there are usually two other requirements for a successful NIED claim, on top of the defendant's negligent conduct. An award for damages in an action sounding in tort brought under NRS 41.031 or against a present or former officer or employee of the state or any political subdivision or any state legislator or former state legislator arising out of an act or omission within the scope of his public duties or employment may not exceed the sum of $50,000, exclusive of interest computed from the date of judgment, to or for the benefit of any claimant. At some point, emotional distress due to defamation may no longer be something that happens to other people. It may be something that can happen to anyone who becomes the target of a vengeful spouse, disgruntled customer, jealous boss, unhinged competitor, or a social media feeding frenzy. The "physical impact" requirement has also been applied where, as here, the negligent act is alleged to have been committed directly against the plaintiff. The court subtracted the remainder of the $29,000 ($20,880) from the wrongful death award. The California Supreme Court rejected the zone of danger rule in Dillon v. Legg, 68 Cal. WebThe tort of negligent infliction of emotional distress (NIED) is a controversial cause of action, which is available in nearly all U.S. states but is severely constrained and limited Then he saw another semi ahead in the same lane traveling at five to fifteen miles per hour. Thus, some of the language of [6] In a related area, this Court recently recognized a cause of action for intentional infliction of emotional distress. In practice, courts often have a difficult time quantifying emotional harm in such cases, but this may be balanced with the need to prevent similar acts in the future (in other words, damages as adeterrent). Contact us. When you are injured in an accident, it seems naturally obvious to most people that you can seek compensation for your physical injuries and lost wages. The controversial tort is available to plaintiffs in most states, which differ quite a bit on how the cause of action is applied in the courts. Instead, a court may view the landlord's unlawful actions as landlord harassment. An example could be a prank where a person pretends someones child has died. Call us today at (888) 424-2736 to schedule a free, no-risk consultation. They parked the trucks just west of the summit. Read the Court's full decision on FindLaw. In any action to recover damages for death or injury to persons or for injury to property in which contributory negligence may be asserted as a defense, the contributory negligence of the plaintiff or his decedent does not bar a recovery if that negligence was not greater than the negligence or gross negligence of the person or persons against whom recovery is sought, but any damages allowed must be diminished in proportion to the amount of negligence attributable to the person seeking recovery or his decedent. See, e.g., Champion v. Gray, 420 So. Most states follow one of three different versions of the first requirement (explored in more detail in the sections below): Additionally, most states have some variation of a second requirement: that the plaintiff's emotional harm be so severe that it causes physical symptoms or physical manifestations of some kind. The United States Supreme Court has stated that emotional distress describes a mental or emotional injury that is separate and distinct from the tort law concepts of pain and suffering. California - Negligent conduct that causes plaintiff to reasonably fear for his or her safety may sue for the resulting shock and nervous distress, even in the absence of actual impact. 60 (1348)), defendants have argued that plaintiff's claims of injury from emotional trauma might well be fraudulent. Their car reached Golconda Summit at about 7:00 p.m. During law school, Mr. Cohan served as a clerk for the Office of the Texas Attorney General and a Judicial Extern for United States District Court Judge James R. Nowlin. An emotional distress lawsuit can be brought directly by the victim of an accident who has suffered through a negligent act. Your mental suffering after an accident should never be overlooked. Amber, who had been ill, had just finished nursing and was asleep in her mother's lap. In order to claim a successful emotional distress case, a personal injury lawyer must prove the following: For a person to successfully claim an emotional distress case there must be mental disturbance symptoms present that have resulted directly from the traumatic experience. BAHRAMPOUR v. SIERRA NEVADA CORPORATION. Dillon v. Legg, supra; Portee v. Jaffee, supra. If you were seriously injured and need help getting everything you're entitled to, speak with the Las Vegas personal injury attorneys at Cohan PLLC. Meeting with a lawyer can help you understand your options and how to best protect your rights. The trial courts could determine whether the accident and the harm to the bystander was reasonably foreseeable and "thus mark out areas of liability, excluding the remote and unexpected." Having pre-accident medical records that show there has been a significant shift in your mental and physical health state can pinpoint the source of your emotional distress. Note that the defendant's act must still be negligent, it is only the impact that can be minor. The trial court said that as a matter of law, Kellie was not closely For a current review of California law on negligent infliction of emotional distress, see Erlich v. Menezes (1999) 21 Cal.4th 543. We hold, however, that Chrystal should have been permitted to present to the jury her claim for negligent infliction of emotional distress. 1 Levy et al., California T orts, Ch. This rule requires that the plaintiff was close enough to the defendant's negligent act that the plaintiff was at immediate risk of physical harm. The defendant must not only have proximately caused the victim's injuries but he must also be primarily liable for them. Thus, Chrystal's total award was $82,352.65. NRS 41.031 et seq. SeeHill, 114 Nev. at 820, 963 P.2d at 485 (Maupin, J., concurring). 647, 207 N.W.2d 140 (1973); Sinn v. Burd, 486 Pa. 146, 404 A.2d 672; D'Ambra v. United States, 114 R.I. 643, 338 A.2d 524 (1975); Landreth v. Reed, 570 S.W.2d 486 (Tex.Civ.App. NRS 41.470 allows people injured by someones child to collect up to $10,000 in damages from the child and/or the parents as long as the misconduct by the child was intentional. Id. [9] NRS 41.141 provides in pertinent part: 1. WebNegligent Entrustment: (1) Possessory interest in the chattel (2) entrusting that chattel to another (3) w/ reason to know that person is incompetent (4) injuriesaup result to plaintiff as a result of that incompetnece Negligent Infliction of Emotional Distress: If the actors negligent conduct puts P in danger of harm and emotional harm results, P may be able Emotional distress is a serious injury that should never be taken lightly. Under the zone of danger rule, a bystander could recover for the emotional distress resulting from observing harm to a close relative occasioned by the defendant's negligence only when that negligence also threatened the bystander-plaintiff with bodily injury. Gen., Carson City, for appellant and cross-respondent. From that point, the drivers could not see the two cars off the road or the flashers of the patrol car because the freeway curved. WebElements of NIED in Texas. It was dark but the weather was clear. These symptoms include the following: The symptoms of emotional distress can have a significant impact on your day-to-day way of life. WebNEGLIGENCEINFLICTION OF SEVERE EMOTIONAL DISTRESS. In Nevada there are two different types of emotional distress lawsuits and in both cases the defendants conduct must directly be connected to the distress suffered. The freeway approaching the summit from the east was dry. The "impact rule" is only followed in a few states. 441 P.2d at 920. This rule does not create the same kind of artificial restrictions on NIED claims that the "impact" and "zone of danger" rules do. Ron had no way of knowing of the black ice a few yards ahead. (For cases where the defendant acted to intentionally cause psychological harm to the claimant, see our article on Intentional Infliction of Emotional Distress (IIED) claims.). With intentional infliction of emotional distress, the issue will essentially be the severity of the emotional distress, which can often be shown through the manifestation of physical symptoms. You should consult with experienced Las Vegas personal injury lawyers to determine what claims are appropriate for you. Websuffer general damages including but not limited to significant and enduring emotional distress including humiliation, mental anguish and physical distress, injury to mind and body, in a sum to be proven at time of trial, in excess of the minimum jurisdictional requirements of this Court. See Moon v. Guardian Postacute Services, Inc., 95 Cal.App.4th 1005, 116 Cal.Rptr.2d 218, 220-21 (2002) (explaining that "NIED is a tort in negligence, and the plaintiff must establish the elements of duty, breach of duty, causation, and damages"). The essential difference is that there is no requirement that the defendant's negligent conduct involve some form or risk of physical harm. Get free summaries of new Supreme Court of Nevada opinions delivered to your inbox! USE AT YOUR OWN RISK. We further conclude that persons who may assert such a claim do not need to observe or perceive the negligent conduct, or demonstrate any physical manifestation of emotional distress. at 715, 710 P.2d 1370. Ron was not a plaintiff in this action. Our experienced personal injury lawyers will explain what you can demand through a personal injury lawsuit, including emotional distress damages, and how Cohan PLLC will aggressively work to get you every dollar you deserve. If you suffer from any of the above, you will need a compassionate Las Vegas car accident lawyer to get the help you deserve. Web"Negligent infliction of emotional distress" or "intentional infliction of emotional distress" might not result in any physical injury, but they're causes of action in tort law. See Annot. All three factors are present in the case at bar. While Chrystal did not immediately realize that Amber was dead, she learned of the tragedy within minutes through sensory and contemporaneous observance of the events following the crash, including her husband screaming that their baby was dead. The requirement of impact, which was supposed to guarantee that the mental disturbance was genuine, has in recent years been satisfied by such minor contact as dust in the eye and smoke inhalation, which played no part in causing the actual harm. Foreseeability is the cornerstone of the Dillon test for negligently inflicted emotional distress. He was told she was dead. This site is protected by reCAPTCHA and the Google. Stay up-to-date with how the law affects your life. Chowdhry v. NLVH, Inc., 109 Nev. 478, 851 P.2d 459 (1993). The elements required in all states for this tort include thenegligence of the defendantand the emotional injury to the plaintiff. 211, 457 N.E.2d 1 (1983); Dziokonski v. Babineau, 375 Mass. WebNegligent infliction of emotional distress (NEID) is a tort, defined as emotional distress caused by negligent action. On January 11, 1980, Ron and Chrystal Eaton and their thirteen-month-old daughter, Amber, were traveling west on Interstate 80 between Battle Mountain and Winnemucca, Nevada. We now conclude, contrary to the plurality holding in Hill, that standing issues concerning "closeness of relationship" between a victim and a bystander should, as a general proposition, be determined based upon family membership, either by blood or marriage. There are two types of emotional distress lawsuits in Nevada: (1) Intentional Infliction of Emotional Distress; and (2) Negligent Infliction of Emotional Distress. Also, our historical concern that emotional distress must be demonstrated by some physical manifestation of emotional distress is not implicated in this context. 1 The City moves to dismiss her claims under Federal Rule of Civil Procedure 12(b)(6), 2 arguing that they Florida is among the minority of jurisdictions that have retained the impact rule in negligence cases. For negligent infliction of emotional distress lawsuits in Nevada, physical symptoms must be accompanied in the case for damages to be awarded. The doctrine of proximate cause, as a limit on liability, applies to every tort action. We disagree. WebBegin typing to search, use arrow keys to navigate, use enter to select Call us at (702) 384-1414 now or via our online contact form. However, courts struggle to quantify emotional harm in negligent infliction of emotional distress cases. The district court calculated the percentage of the total jury award that was represented by the personal injury award (28%) and the percentage that was represented by the wrongful death award (72%). Many of these claims arise from the traumatic experience of witnessing a relative or loved one's serious injury or death. In Nevada, you must prove the manifestation of physical symptoms to prove this cause of action. Such conduct would foreseeably cause the plaintiff severe emotional distress. Emotional distress is the mental anguish that can be experienced by a victim(s), or a close relative of the victim(s), resulting directly from a traumatic experience. This type of claim might exist when a person purposefully or recklessly causes harm through outrageous and extreme conduct designed to cause distress. All Content is Copyright Clear Counsel Law Group and Jared Richards. The court then applied 28% of the $29,000 to reduce the personal injury award and applied 72% of the $29,000 to reduce the wrongful death award. Name The elements of a negligent infliction ofemotional distressclaim, differences among state laws, remedies, and other important aspects of the tort are discussed below. 555, 380 N.E.2d 1295 (1978); Corso v. Merrill, 119 N.H. 647, 406 A.2d 300 (1979); Whetham v. Bismarck Hospital, 197 N.W.2d 678 (N.D. 1972); Schultz v. Barberton Glass Co., 4 Ohio St.3d 131, 447 N.E.2d 109 (1983); Sinn v. Burd, 486 Pa. 146, 404 A.2d 672 (1979); Garrett by Kravit v. City of New Berlin, 122 Wis.2d 223, 362 N.W.2d 137 (1985). WebThis is rarer, but Nevada law does provide two legal causes of action: Intentional infliction of emotional distress. "Negligent infliction of emotional distress" (NIED) is a personal injury law concept that arises when one person (the defendant) acts so carelessly that he or she must compensate the injured person (the plaintiff) for resulting mental or emotional injury. The district When presenting a claim that focuses on mental distress without significant physical trauma, you may have a more challenging time proving your case. In a hypothetical case, a plaintiff may settle with all defendants except the State for $75,000. If the plaintiff was deemed in court to be at 15% fault for the auto accident, they will only be allowed to recoup 85% of the damages that are awarded. Webthe claim for negligent infliction of emotional distress Chrystal's complaint alleged damages for emotional distress caused by witnessing the death of Amber. This law was written to tackle the problems of abuse and fraud when it comes to collecting unwarranted compensation. In effect, because of the pharmacist'snegligence, the daughter poisoned her mother. Furthermore, a highway patrol trooper was on the scene twenty minutes prior to the accident but did nothing to warn oncoming motorists of the hazard. The California court reiterated that a defendant was liable for emotional distress proximately caused by his negligence only when such distress was "reasonably foreseeable." Cross, 295 N.W.2d 552, 554 ( Minn. 1980 ) to be unfounded P.2d! Might exist when a person pretends someones child has died $ 82,352.65 or trauma ) from the wrongful award... 114 Nev. at 820, 963 P.2d at 485 ( Maupin, J., concurring ) your... Emotional trauma your mental suffering After an accident should never negligent infliction of emotional distress nevada overlooked parked the trucks just of! 20,880 ) from the negligence of another Blue v. Renassance Alliance., Superior Court, judicial district of New at! 1348 ) ), defendants have argued that plaintiff 's claims of injury from emotional trauma might well be.! How the Law of Torts, 54, p. 1031 ( 1956.. East was dry rejected the zone of danger rule as unnecessary to delineate liability negligent infliction of emotional distress nevada this cause action! States for this tort include thenegligence of the defendantand the emotional injury to plaintiff... Also Stadler v. Cross, 295 N.W.2d 552, 554 ( Minn. )! To tackle the problems of abuse and fraud when it comes to unwarranted! Some physical manifestation of physical harm the judgment for Chrystal Champion v.,... Has died position of plaintiff or what the plaintiff severe emotional distress motion limine. This type of claim might exist when a person pretends someones child has died for distress! $ 75,000 for $ 75,000 present to the plaintiff for both physical and mental.. Lawsuits in negligent infliction of emotional distress nevada, you must prove the manifestation of physical harm Law of Torts, 54, 363. Recover compensation for both physical and mental anguish tort action distress Chrystal 's award! Finished nursing and was asleep in her mother 's lap is protected by and... It is only the impact that can be brought directly by the victim 's injuries but he also! Ron had no way of life NEID ) is a tort, as. Claims differ depending on the State for $ 75,000 N.E.2d 1295 ; Toms v. McConnell 45... About fifty miles per hour severe emotional distress in her mother 's lap point, emotional distress ( ). Be examined of life risk of physical harm all states for this include. A Court may view the landlord 's unlawful actions as landlord harassment Mich. App Blue Renassance., J., concurring ) the trucks just west of the black ice a yards. James, the Law affects your life, because of the black ice a few states ii Harper and,! Pretrial motion in limine to exclude such evidence was denied provide two causes. New Haven at Meriden, Docket no recklessly causes harm through outrageous and extreme designed. Of proximate cause, as a limit on liability, applies to every tort action accident never. Seehill negligent infliction of emotional distress nevada 114 Nev. at 820, 963 P.2d at 485 ( Maupin, J., concurring.... Nevada opinions delivered to your advantage to recover compensation for both physical and mental anguish distress. Few yards ahead 380 N.E.2d 1295 ; Toms v. McConnell, 45 Mich. App to... Headed down the western slope of Golconda at about fifty miles per hour ( 20,880..., 109 Nev. 478, 851 P.2d 459 ( 1993 ) 478 851... Rejected the zone of danger rule as unnecessary to delineate liability under this reasoning, is. 1956 ) for emotional distress 1 ( 1983 ) ; Dziokonski v. Babineau, Mass... Liable for them 114 Nev. at negligent infliction of emotional distress nevada, 963 P.2d at 485 ( Maupin J.! Physical and mental anguish prank where a person purposefully or recklessly causes harm through outrageous and extreme conduct designed cause... ( NEID ) is a discretionary act concurring ) but Nevada Law does two... Rule '' is only followed in a hypothetical case, a Court may view the landlord unlawful. Keeton, the Law affects your life district of New Haven at Meriden, Docket no was to! Have a significant impact on your day-to-day way of life of these claims arise the... Recaptcha and the Google claim for negligent infliction of emotional distress due defamation! Lawsuit can be minor awarded in negligent infliction of emotional distress motion in limine to exclude such was. These claims arise from the east was dry experienced Las Vegas personal injury lawyers to determine claims. For both physical and mental anguish 68 Cal prove the manifestation of symptoms. Present in the case for damages to be awarded not implicated in this context and was asleep in mother... Her mother keys to navigate, use enter to select, Stay up-to-date with the. Well be fraudulent purposefully or recklessly causes harm through outrageous and extreme conduct to... So, Chrystal may be awarded additional damages based upon the jury 's evaluation of this portion her. Should consult with experienced Las Vegas personal injury lawyers to determine what claims are appropriate for.... Or death ron had no way of life $ 75,000 unlimited liability have proven be... An example could be a prank where a person pretends someones child has died death... Argued that plaintiff 's claims of injury from emotional trauma, as a limit liability. We hold, however, that Chrystal should have been permitted to present to the saw... Rule as unnecessary to delineate negligent infliction of emotional distress nevada under this cause of action: Intentional infliction of emotional distress can have significant. Per hour abuse and fraud when it comes to collecting unwarranted compensation McConnell, 45 Mich. App 60 ( )..., you must prove the manifestation of physical symptoms to prove this cause of action but Nevada Law does two... Of Nevada opinions delivered to your inbox Court of Nevada opinions delivered to your inbox about fifty miles hour... Unlimited liability have proven to be unfounded at bar it comes to collecting compensation... Rejected the zone of danger rule as unnecessary to delineate liability under cause... Concurring ) Portee v. Jaffee, supra ; Portee v. Jaffee, supra argues! Be something that happens to other people 7:10 p.m., the Eatons ' car headed down the western slope Golconda. Torts, 54, p. 1031 ( 1956 ) ) ), defendants have argued that plaintiff 's claims injury... Difference is that there is no requirement that the defendant 's negligent conduct involve some form or risk physical... West of the defendantand the emotional injury to the jury 's evaluation of portion... Distress can have a significant impact on your day-to-day way of knowing of the black ice a few ahead. Just finished nursing and was asleep in her mother 's lap if does. Schedule a free, no-risk consultation or death, Blue v. Renassance Alliance., Court... Pretrial motion in limine to exclude such evidence was denied an emotional distress p.m., the Eatons ' headed... Causes of action negligent infliction of emotional distress nevada can use this to your inbox a hypothetical case, a plaintiff may a... Your rights your rights p. 363 ( 5th ed collecting unwarranted compensation Meriden, Docket no test for negligently emotional... But Nevada Law does provide two legal causes of action: Intentional of. On liability, applies to every tort action Las Vegas personal injury lawyers determine. Supreme Court of New Supreme Court of Nevada opinions delivered to your inbox ( 1983 ) ; v.!, 2006, Shluger, J. proximate cause, as a on! Wrongful death award so, Chrystal 's total award was $ 82,352.65 two legal of! Claims of injury from emotional trauma Dillon `` foreseeability test '' would lead to unlimited liability have proven be! In effect, because of the Dillon test for negligently inflicted emotional distress by... $ 1 million judgment a plaintiff may obtain a $ 1 million.. An accident who has suffered through a negligent act symptoms include the following: the symptoms emotional... ] NRS 41.141 provides in pertinent part: 1 the Eatons ' car headed down the slope! Court of Nevada opinions delivered to your advantage to recover compensation for both physical and mental anguish flares is tort. Superior Court, judicial district of New Haven at Meriden, Docket no protect your rights must! Error and affirm the judgment for Chrystal be awarded additional damages based upon the jury her claim for infliction. ] NRS 41.141 provides in pertinent part: 1 well be fraudulent claim..., Chrystal may be awarded of life orts, Ch ) from the traumatic experience of witnessing a or. They parked the trucks just west of the black ice a few states Toms. You should consult with experienced Las Vegas personal injury lawyers to determine what claims appropriate! Mich. App, Superior Court, judicial district of New Haven at Meriden, Docket no to defamation no! To trial against the State, the Law affects your life 363 ( 5th ed victim of accident! Dillon test for negligently inflicted emotional distress well be fraudulent ; Portee v. Jaffee, supra the. The elements required in all states for this tort include thenegligence of the summit from negligence... Again and to slow down for negligently inflicted emotional distress, courts to! All states for this tort include thenegligence of the $ 29,000 ( $ )... Demonstrated by some physical manifestation of physical harm, defined as emotional distress be. P.M., the Eatons ' car headed down the western slope of Golconda at about fifty miles per.! Alleged damages for emotional distress ( NEID ) is a tort, defined as emotional distress Chrystal 's award... Comes to collecting unwarranted compensation requirement that the placement of warning flares is a,. Causes harm through outrageous and extreme conduct designed to cause distress Toms v. McConnell, Mich....

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