Before examining the standards set forth by the Ohio Supreme Court in Paugh v. Hanks, a brief overview of the history and treatment of emotional distress in other jurisdictions is necessary because Ohio has borrowed from the experiences and illustrations of several states in delineating the standards for administration of this new tort.
Morrell, Dan A. Jr.
"Administering Ohio's Newly Recognized Tort: The Negligent Infliction of Serious Emotional Distress,"
Akron Law Review: Vol. 17:
4, Article 4.
Available at: https://ideaexchange.uakron.edu/akronlawreview/vol17/iss4/4