## Facts

- A gas explosion and resulting fire occurred near where Stevenson (plaintiff) lived or worked in Cleveland, Ohio.
- Stevenson alleged the explosion and fire were caused by East Ohio Gas Co.’s (defendant’s) negligent conduct in operating its gas facilities.
- Stevenson was not physically injured by the event.
- Stevenson did not allege that his own property was damaged.
- Stevenson did not report to work for about eight days after the explosion and fire, claiming he was afraid for his personal safety if he returned to the area.
- Stevenson sued East Ohio Gas Co. seeking to recover the wages he lost during the period he stayed away from work.
- The trial court sustained the defendant’s demurrer (dismissed the petition for failure to state a claim), and Stevenson appealed.

## Issues

1. Whether a plaintiff states a negligence claim for lost wages when the plaintiff alleges no physical injury and no damage to the plaintiff’s property, and the wage loss results from the plaintiff’s fear after a nearby explosion and fire allegedly caused by the defendant.

## Decision

- The Ohio Court of Appeals affirmed the trial court’s judgment sustaining the demurrer.
- The court held that Stevenson could not recover in negligence for lost wages based only on fear and absence from work, where he alleged no injury to his person and no injury to his property.
- The court treated the claimed damages as purely economic and too remote to support negligence liability on the pleaded facts.

## Legal Principles

- Negligence liability generally requires an invasion of a legally protected interest, and purely economic loss, standing alone, is not enough to create a negligence cause of action.
- Lost earnings may be recovered as damages when they flow from a recognized injury (such as bodily harm or property damage), but not when the only alleged harm is economic loss from disrupted work.
- Fear or apprehension, without alleged physical impact, bodily injury, or property damage, does not convert a wage-loss claim into an actionable negligence injury.
- Courts limit negligence liability for indirect economic consequences of accidents in part to avoid open-ended claims by large numbers of people indirectly affected by a single event.

## Conclusion

In *Stevenson v. East Ohio Gas Co.*, the Ohio Court of Appeals held that a worker who stayed home for about eight days after a nearby explosion and fire, out of fear for his safety, could not recover lost wages in negligence where he alleged no physical injury and no damage to his own property. The court affirmed dismissal on demurrer, treating the claimed wage loss as an indirect, purely economic consequence that Ohio negligence law did not recognize as an independent basis for recovery.


Stevenson v. East Ohio Gas Co., 73 N.E.2d 200 (1946)