Mitchell v. Rochester R. Co. - 151 N.Y. 107, 45 N.E. 354 (1896)

Rule:

No recovery can be had for injuries sustained by fright occasioned by the negligence of another where there is no immediate personal injury.

Facts:

While the claimant was about to board a car operated by the railroad, an approaching horse car belonging to the railroad frightened her. The fright caused a miscarriage and a consequent illness. She brought a negligence suit against the roailroad for the injuries she sustained.

Issue:

Was the claimant entitled to recover for her injuries?

Answer:

No

Conclusion:

The Court held that the claimant was not entitled to recovery based on the railroad's negligence. The court held that no recovery was available for mere fright where there was no immediate personal injury and where the resulting miscarriage was not the proximate result of the railroad's negligence. The court found that the injuries were too remote and unforeseeable for recovery, and that the injuries were the result of an accident that was not reasonably anticipated and over which the railroad had no control.