## Facts

- Bobby L. Camper, III drove a cement truck on South Wilcox Drive in Kingsport, Tennessee.
- Sixteen-year-old Jennifer L. Taylor, driving a car owned by Sharon R. Barnett, entered the intersection from Reservoir Road, which was controlled by a stop sign.
- Taylor, after stopping, pulled into Camper’s path; the vehicles collided, and Taylor died at the scene.
- Immediately after the collision, Camper exited his truck, walked to the front, and saw Taylor’s body in the wreckage from close range.
- Camper alleged no substantial physical injury, but claimed serious emotional harm (including post-traumatic-type symptoms) and sought psychiatric treatment.
- Camper sued Taylor’s estate (through an administrator ad litem) and Barnett, seeking damages for negligent infliction of emotional distress and asserting Barnett’s liability as vehicle owner under the family purpose doctrine.

## Issues

1. Whether a non-negligent driver who suffers no substantial physical injury may recover for negligent infliction of emotional distress under these facts.
2. Whether Tennessee’s family purpose doctrine survives the adoption of comparative negligence and the abolition of joint and several liability.

## Decision

- The Tennessee Supreme Court reversed the Court of Appeals’ summary judgment for defendants and remanded for further proceedings.
- The Court rejected rigid NIED gatekeeping rules that required physical injury or fear for one’s own safety (and, in some settings, a close relationship to the injured person) as absolute prerequisites to recovery.
- The Court held NIED claims are analyzed under ordinary negligence elements, with an added requirement that the plaintiff prove a serious emotional injury through competent expert medical or scientific proof.
- The Court held the family purpose doctrine remains valid despite Tennessee’s comparative fault regime and the abolition of joint and several liability.

## Legal Principles

- Negligent infliction of emotional distress is not an independent tort; it is a negligence claim in which the alleged injury is emotional rather than physical.
- A plaintiff seeking emotional-distress damages must prove duty, breach, causation, and damages, including a serious emotional injury.
- Physical injury, physical manifestation, or fear for one’s own safety is not a categorical prerequisite to recovery; such considerations may bear on foreseeability and duty but do not operate as absolute bars.
- Serious emotional injury must be supported by competent expert medical or scientific evidence to screen out trivial or speculative claims.
- The family purpose doctrine continues to impose vicarious liability on a vehicle owner who provides and controls a vehicle for family use when a family member negligently operates it for a family purpose, notwithstanding comparative negligence and the abolition of joint and several liability.

## Conclusion

The court modernized Tennessee emotional-distress law by treating NIED as a standard negligence claim requiring expert proof of serious emotional injury, and it reaffirmed that the family purpose doctrine remains a viable basis for vicarious liability under Tennessee’s comparative fault system.


Camper v. Minor, 915 S.W.2d 437 (Tenn. 1996)