This Note will first trace the development of the negligent infliction of emotional distress in North Carolina case law. Second, the Note will explain the limitations on recovery adopted in other jurisdictions and explore the policies behind those limitations. Finally, this Note will analyze the Johnson decision by comparing its holding to the recent national trend and by noting problems that the North Carolina Supreme Court did not adequately address.
Donna L. Shumate, Tort Law: The Negligent Infliction of Emotional Distress - Reopening Pandora's Box - Johnson v. Ruark Obstetrics, 14 Campbell L. Rev. 247 (1992).