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  • Armstrong v. Paoli Memorial HospitalArmstrong v. Paoli Memorial Hospital
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Armstrong v. Paoli Memorial Hospital

Superior Court of Pennsylvania
633 A.2d 605 (1993)


One morning Dawn Armstrong (plaintiff) received a call from an emergency-room employee at Paoli Memorial Hospital (Paoli) (defendant). The employee informed Armstrong that her husband, Thomas Armstrong, had been in an accident and was in critical condition. Upon arriving at the hospital, Dawn was not permitted to see the injured man. Dawn met with a neurosurgeon to discuss x-rays of the man’s crushed cranium. More than an hour after arriving, Dawn’s sister saw the driver’s license of the injured man, and discovered that the accident victim was Thomas H. Armstrong. Dawn’s husband was Thomas J. Armstrong. Upon learning that the accident victim was not her husband, Dawn became very upset and lost control of her bowels. Dawn later suffered depression, nightmares, and insomnia. Dawn met with a counselor to treat unreasonable fears relating to her husband’s wellbeing. Dawn sued Paoli for, among other things, the negligent infliction of emotional distress. A jury awarded Dawn $1,000 in damages. The trial court granted a new trial for damages and denied Paoli’s motion for judgment notwithstanding the verdict. Paoli appealed.

Rule of Law


Holding and Reasoning (Cirillo, J.)

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