Miller v. Willbanks
Tennessee Supreme Court
8 S.W.3d 607 (1999)
- Written by Craig Conway, LLM
Facts
Shortly after delivering a baby, Elizabeth Ann Miller was accused of being a drug abuser by David Willbanks, M.D. (defendant). The basis of Dr. Willbanks’s claim was that the newborn exhibited symptoms of Drug-Withdrawal Syndrome. Dr. Willbanks spread his suspicions among the hospital staff and to Miller’s parents prior to confronting Miller. Miller agreed to a drug test, which came back negative. Despite the test’s negative results, Dr. Willbanks continued to spread his claims and reported Miller to the local health department. Miller and her husband (plaintiffs) filed suit against Dr. Willbanks and others (defendants) for intentional infliction of emotional distress (IIED). The trial court granted summary judgment to the defendants because the Millers failed to present expert evidence to support the claim that Elizabeth Ann suffered serious mental injury as a result of the defendants’ actions. The Millers appealed. The court of appeals affirmed, holding that expert medical or scientific proof of a serious mental injury was required to support the Millers’ claim for IIED. The Supreme Court of Tennessee granted certiorari to review.
Rule of Law
Issue
Holding and Reasoning (Barker, J.)
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