Karen Williamson and James Williamson, Her Husband, Plaintiffs-Respondents v. Leonard Waldman, M.D., Jeffrey…

Summary

The Supreme Court of New Jersey affirmed the Appellate Division’s reversal of the trial court’s summary judgment, holding that a plaintiff need not prove actual exposure to HIV to recover for negligent infliction of emotional distress; instead, recovery is governed by an enhanced reasonableness standard that requires the plaintiff’s fear to be reasonable as measured by a reasonably well‑informed person with current public information about AIDS. The Court further held that emotional distress caused by later erroneous medical advice is not proximate cause of the original defendants’ negligence and therefore not recoverable.