Section 12 Emotional Distress From an Intentional Tort Does Not Require Medical Testimony to Establish
| Library | Damages 2012 |
In State ex rel. Dean v. Cunningham, 182 S.W.3d 561 (Mo. banc 2006), the Supreme Court of Missouri adopted appellate courts’ holdings that no medical testimony is needed to show emotional distress from intentional torts. Id. at 568 (citing Fust v. Francois, 913 S.W.2d 38 (Mo. App. E.D. 1995), and Lipari v. Volume Shoe Corp., 664 S.W.2d 953 (Mo. App. W.D. 1983)). The plaintiff in Cunningham claimed damages for emotional distress from sex discrimination and sexual harassment under the Missouri Human Rights...
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