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Patterson v. Wu Family Corporation

Minnesota Court of Appeals
594 N.W.2d 540 (1999)


Facts

Arthur Patterson (plaintiff) went to the Nankin Café with a group of friends. The Nankin Café, owned by the Wu Family Corporation (Wu Family) (defendant), hired Henry Price as a bouncer for the café. On the night Patterson and his friends went to the café, Price cleared a table for them and told them they would have to go to the bar to order drinks. At that time, Price did not request identification from Patterson to confirm he was of legal drinking age. One of Patterson’s friends bought Patterson an alcoholic drink from the bar and brought it to the table. Price then asked Patterson for his identification, and Patterson told Price that he did not have any. Price instructed Patterson to leave, and as Patterson was leaving, Price grabbed his arm, twisted it, and pushed Patterson out of the café, causing Patterson to fear harm. Patterson claimed that, as a result of this incident, he developed high blood pressure and muscle strains. His doctors were unable to determine the cause of the high blood pressure. Patterson also claimed that as a result of the incident with Price, he developed a fear of being in public places, but he did not seek treatment for such fear. Patterson brought suit against Price and Wu Family for intentional and negligent infliction of emotional distress. The trial court granted summary judgment in favor of Wu Family, and Patterson appealed.

Rule of Law

Issue

Holding and Reasoning (Peterson, J.)

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