## Facts

- F. H. Sander had a dispute with Emma White’s father.
- Emma White was inside her father’s house.
- From outside, Sander intentionally threw a rock through a closed window, intending to damage the house.
- Sander did not know Emma was in the room behind the window.
- Emma suffered bodily injury attributed to fright caused by the rock’s entry, rather than from being struck by the rock.
- Emma sued Sander in tort and obtained a plaintiff’s judgment; Sander appealed.

## Issues

1. Whether a defendant who intentionally damages property by throwing a rock through a window is liable for bodily injury suffered by an occupant from fright, when the defendant neither intended to harm the occupant nor knew of the occupant’s presence.
2. Whether bodily harm that follows fright, without direct physical impact, is compensable when the defendant’s conduct is intentional and wrongful.

## Decision

- The Supreme Judicial Court of Massachusetts affirmed the judgment for Emma White.
- The court held Sander liable for White’s bodily injuries resulting from fright caused by his intentional, wrongful rock-throwing.
- Lack of knowledge of White’s presence and lack of intent to injure her personally did not defeat liability.

## Legal Principles

- An actor who commits an intentional, wrongful act that directly causes fright may be liable for resulting bodily injury, even if the harm occurs without physical impact.
- Liability may extend to persons foreseeably endangered or terrified by the intentional act, even if the actor did not know the specific person was present.
- In intentional-tort settings, a defendant may be responsible for the direct and natural consequences of the wrongful act, including medically cognizable physical injury precipitated by fright.

## Conclusion

The court sustained recovery for bodily injury produced by fright where the defendant intentionally committed a wrongful, dangerous act directed at property, and the plaintiff’s injury directly resulted from the fear induced by that act despite the defendant’s lack of intent to harm her and ignorance of her presence.


White v. Sander, 47 N.E. 90 (Mass. 1897)