Squeo v. Norwalk Hospital Assn.

Summary

The court held that Connecticut recognizes a narrowly limited bystander emotional-distress claim arising from medical malpractice when the claimant satisfies the existing bystander requirements and contemporaneously observes gross professional negligence that is apparent to a layperson and likely to cause serious injury or death. It further held that the emotional distress must be severe and debilitating, either warranting a psychiatric diagnosis or substantially impairing the claimant’s ability to cope with daily life. The court affirmed summary judgment because the plaintiffs offered no evidence creating a genuine issue that their distress met that standard.