Hawkins v. Diel, 166 Wash. App. 1 (2011)

Citation: Hawkins v. Diel, 166 Wash. App. 1 (2011)
Parent Document: Hawkins v. Diel, 166 Wash. App. 1 (2011)
Jurisdiction: Washington (state)
Effective Date: 2011-11-18
Original Source: https://www.courtlistener.com/opinion/4950936/hawkins-v-diel/ ↗

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¶29 The Hawkinses nonetheless argue that under Price v. State, 114 Wn. App. 65, 73, 57 P.3d 639 (2002), *15they need not prove objective symptomatology where they have a preexisting relationship with the defendant. They are not persuasive. Price synthesized decades of the law surrounding negligent infliction of emotional distress and formulated helpful rules, including the following: If the relationship between the parties was more than merely economic, and a reasonable person standing in the defendant’s shoes would easily foresee that breach of its duty to the plaintiff is likely to cause significant emotional distress, damages need not be supported by proof of physical impact or objective symptomatology. Price, 114 Wn. App. at 73.

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