Armstrong v. Paoli Memorial Hospital Case Brief Summary | Law Case Explained

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Armstrong v. Paoli Memorial Hospital | 633 A.2d 605 (1993)

Hearing that a loved one has been seriously injured is distressing news. But what if someone found out she only went through that distress because of someone’s mistake? In Armstrong versus Paoli Memorial Hospital, we’ll explore whether plaintiffs have an avenue to recover for negligent infliction of emotional distress.

Thomas Armstrong was critically injured in an accident and was brought unconscious to Paoli Memorial Hospital’s emergency room. A hospital employee asked the telephone operator for Thomas Armstrong’s number and was connected to Dawn Armstrong. He told Dawn that her husband was in critical condition. At the hospital, Dawn wasn’t permitted to see Thomas but met with the neurosurgeon and was shown X-rays of a crushed cranium. Dawn was at the hospital for over an hour when her sister noticed Thomas Armstrong’s driver’s license. Instead of Dawn’s husband’s name, Thomas J. Armstrong, the license was for Thomas H. Armstrong. Dawn lost control of her composure and her bowels when she found out the injured man wasn’t her husband. As a result, she suffered from and received counseling for depression, nightmares, insomnia, and unreasonable fears about her husband’s well being.

Armstrong sued Paoli Memorial for negligent infliction of emotional distress in a Pennsylvania state trial court. A jury found in Armstrong’s favor and returned a one thousand dollar verdict. The trial court denied Paoli Memorial’s motion for a judgment notwithstanding the verdict and granted Armstrong’s motion for a new trial on damages only. Paoli Memorial appealed to the Pennsylvania Superior Court.

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