## Facts

- Oliver H. Bosley and Mary Louise Bosley owned a farm adjoining Dale Andrews’s farm.
- Andrews owned cattle, including a Hereford bull.
- Andrews’s cattle escaped onto the Bosleys’ farm and damaged crops; a jury later awarded \$179.99 for the crop damage.
- During efforts to drive the cattle, the bull charged toward Mrs. Bosley, causing her to run and collapse.
- The bull did not strike or touch Mrs. Bosley and did not come closer than roughly 25 feet before stopping or being diverted.
- Mrs. Bosley had preexisting arteriosclerosis and coronary disease; she alleged the fright triggered coronary insufficiency and resulting heart disability.

## Issues

1. Whether a plaintiff may recover for physical harm allegedly caused by fright or emotional shock where the defendant’s conduct caused no physical impact or bodily injury to the plaintiff.

## Decision

- The Supreme Court of Pennsylvania affirmed the nonsuit on Mrs. Bosley’s personal-injury claim.
- The court held that, under Pennsylvania law, recovery is barred for physical injury claimed to result from fright or nervous shock absent physical impact or bodily injury.
- The crop-damage verdict remained unaffected.

## Legal Principles

- Under Pennsylvania’s impact rule, there is no recovery for harm attributed to fear, fright, or nervous shock unless accompanied by physical impact or bodily injury.
- Medically verified physical consequences allegedly triggered by fright do not satisfy the impact requirement if no external physical contact or trauma occurred.
- The impact rule functions as a categorical limitation intended to prevent speculative or fraudulent claims and to maintain administrable boundaries on liability.

## Conclusion

Because Mrs. Bosley experienced no physical impact or bodily injury from the bull’s charge, Pennsylvania’s impact rule barred her claim for a heart disability allegedly triggered by fright, and the nonsuit was properly affirmed.


Bosley v. Andrews, 393 Pa. 161, 142 A.2d 263 (Pa. 1958)