Supreme Court of Virginia

Danny Lee Womack v. Rosalie Eldridge

December 2, 1974215 Va. 338

Summary

The court held that a plaintiff may recover for severe emotional distress without bodily injury when the defendant intentionally or recklessly engages in extreme and outrageous conduct that causes the distress. Applying that rule, the court concluded that the evidence permitted reasonable jurors to find the defendant liable and reinstated the jury's verdict. The court declined to consider the defendant's additional challenges because she had not assigned cross-error.