In most courts the tort of emotional distress requires evidence of physical injury to the victim.

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In some jurisdictions, a plaintiff can recover for emotional distress without showing physical injury. This is known as the "impact rule." However, other jurisdictions may require physical injury or some other type of accompanying physical symptoms to establish a claim for emotional distress. It varies by jurisdiction and the specific facts of each case.

In Most Courts the Tort of Emotional Distress Requires Evidence