Minnesota
How Andrews v. United Airlines, Inc. applies in Minnesota: state-specific rules, key cases, and bar exam notes for Torts.
Minnesota follows similar principles to those established in Andrews v. United Airlines, emphasizing the necessity of demonstrating negligence in cases of emotional distress and the applicability of bystander liability. The state recognizes the importance of a defendant's conduct in determining the appropriateness of damages awarded for both physical and emotional harms.
In Minnesota, a plaintiff can recover for negligent infliction of emotional distress only if they are a direct victim or a bystander who witnessed a traumatic event involving a close family member, as established in 'Dunham v. Roer,' 728 N.W.2d 153 (Minn. 2007).
The court allows recovery for emotional distress only if the plaintiff is either directly involved in the incident or is a close relative present at the scene.
Bystander liability can be established if the emotional distress was a foreseeable result of the defendant's negligent conduct.
Emphasizes that emotional distress claims must be tied to significant emotional harm directly linked to a defendant's negligent actions.
In federal law, the principles established under Andrews are generally aligned with the requirement for proving negligence and the possibility of recovery for emotional distress. However, federal courts may have more stringent standards for establishing bystander claims compared to Minnesota's approach, which emphasizes familial relationships.
Cases like Andrews v. United Airlines, Inc. are often referenced in Minnesota bar exams, particularly in issues concerning negligence and recovery standards for emotional distress.