CAMPBELL
v.
OKALOOSA COUNTY SCHOOL DISTRICT

Fla. 1st DCA | 2024-04-10
No. 2023-0659
276 So. 3d 878 Florida District Court of Appeal, First District (2024) Positive Treatment
Cited by 4 cases

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Holding

The impact rule bars recovery for purely emotional harm without accompanying physical injury, and the limited Rowell exception did not apply.


Headnotes

[1] Under the impact rule, a plaintiff may not recover damages for emotional distress unaccompanied by physical injury unless the narrow exception established in Rowell v. …

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Facts & Procedural History

Campbell sued Okaloosa County School District seeking damages for emotional harm. The trial court dismissed the claim based on the impact rule.…

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Opinion of the Court

April 10, 2024 PER CURIAM.

AFFIRMED. See Reid v. Daley, 276 So. 3d 878, 880-881 (Fla. 1st DCA 2019) (applying the impact rule where Appellant’s harm was emotional in nature and the very limited exception to the impact rule established in Rowell v. Holt, 850 So. 2d 474 (Fla. 2003) did not apply). OSTERHAUS, C.J., and ROBERTS and M.K. THOMAS, JJ., concur.

_____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331.


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