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300 N.W.2d 104

Barnhill v. Davis

Supreme Court of Iowa

Decided January 14, 1981

Supreme Court of Iowa · decided 1981-01-14

Relies on Dillon v. Legg · 85 Wash. 2d 52 - Grimsby v. Samson · Tobin v. Grossman

Good law ✅— No negative treatment on recordhow we know

Decided 1981-01-14

How this case has been cited

Cited by 67 later decisions (1 by the Supreme Court) — most recently July 2013 · most notably Atchison Topeka and Santa Fe Railway Company v. Buell (1987), Clohessy v. Bachelor (1996)

2 federal appellate · 3 district · 55 state decisions — followed in 19 states

3601981199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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*109ALLBEE, Justice

¶1(dissenting).

¶2Until today a damage action for the emotional distress of an unendangéred bystander who witnessed the negligent infliction of harm on another person was not recognized as a tort in this state. I am unwilling to join the court in its embracing of this beguiling concept. It is complex, fraught with problems and difficult to administer, as is conceded by even its most ardent supporters. E.g., W. Prosser, The Law of Torts, § 54 at 328-30, 333-35 (4th ed. 1971). Substantial factors militating against the cause of action include the remoteness of emotional distress from the negligent act, the fictional duty of one person to prevent another from being frightened by what he may by chance observe, the problem of the foreseeability of who may be distressed by an act, the nearly limitless possibilities for liability as well as the potential for fraudulent, collusive and nuisance claims. There is no point, however, in belaboring these concerns as they already have been the subject of considerable discussion by respectable authority. See, e.g., Dillon v. Legg, 68 Cal.2d 728, 748-52, 69 Cal.Rptr. 72, 85-88, 441 P.2d 912, 925-28 (1968) (Burke, J., dissenting); Stadler v. Cross, 295 N.W.2d 552, 553-55 (Minn.1980); Tobin v. Grossman, 24 N.Y.2d 609, 613-19, 301 N.Y.S.2d 554, 556-62, 249 N.E.2d 419, 421-24 (1969); Whetham v. Bismarck Hospital, 197 N.W.2d 678, 680-85 (N.D.1972); Shelton v. Russell Pipe and Foundry Co., 570 S.W.2d 861, 862-66 (Tenn.1978); Grimsby v. Samson, 85 Wash.2d 52, 55-57, 530 P.2d 291, 293-94 (1975). But neither these authorities nor I have succeeded in dissuading this court. Thus, I now simply record that I am not a party to the opening of this “Pandora’s box.”

¶3LeGRAND, J., joins in this dissent.

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