Gray, D. v. Huntzinger, A.
147 A.3d 924
Pa. Super. Ct.2016Background
- Plaintiff Dwayne Gray, a CPS employee, alleged that Operations Manager Allen Huntzinger grabbed his arm during a meeting on April 19, 2011, followed by a hallway bump; Gray claimed humiliation and a Crohn’s flare-up requiring ambulance transport.
- Gray sued Huntzinger and Central Parking Systems, Inc. for assault, battery, and intentional infliction of emotional distress (IIED), seeking compensatory and punitive damages.
- At trial the jury found for defendants on assault and battery but found for Gray on IIED, awarding $15,000 compensatory and $52,500 punitive damages total ($2,500 against Huntzinger; $50,000 against CPS).
- Defendants moved for JNOV, new trial, and remittitur; the trial court denied post-trial relief. Defendants appealed.
- The Superior Court considered whether Kazatsky requires expert medical evidence to prove IIED and whether any exception applies when physical impact is alleged.
- The Superior Court concluded Kazatsky mandates competent medical evidence to support claimed emotional distress for IIED claims, and reversed the judgment because Gray presented no such expert testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether expert medical testimony is required to recover for IIED | Gray argued expert proof is unnecessary where conduct involved physical impact and causal link to injury is direct/obvious | Appellants argued Kazatsky requires expert medical evidence to prove emotional distress for IIED | Court held Kazatsky requires competent medical evidence of emotional distress for IIED; absence of such evidence mandates reversal |
| Whether evidence supported IIED liability against Huntzinger | Gray relied on testimony of grabbing, humiliation, and medical consequence (Crohn’s flare-up) | Appellants pointed to witness testimony denying grabbing and characterizing contact as de minimis | Court did not reach merits because claim failed for lack of medical proof |
| Whether punitive damages award was supported | Gray relied on jury finding of outrageous conduct to justify punitive damages | Appellants argued punitive award unsupported without IIED liability and insufficient evidence of outrageousness | Court did not address punitive damages issue after reversing IIED verdict for lack of medical evidence |
| Whether JNOV or new trial was warranted | Gray opposed post-trial relief | Appellants sought JNOV/new trial based on insufficient evidence and lack of medical proof | Court granted reversal of judgment (effectively JNOV) for failure to present expert medical evidence for IIED |
Key Cases Cited
- Kazatsky v. King David Memorial Park, Inc., 527 A.2d 988 (Pa. 1987) (requires competent medical evidence to prove emotional distress in IIED claims)
- Hackney v. Woodring, 652 A.2d 291 (Pa. 1994) (Supreme Court action reinforcing Kazatsky’s requirement where prior panel had allowed recovery without expert proof)
- Cassell v. Lancaster Mennonite Conference, 834 A.2d 1185 (Pa. Super. 2003) (reiterates expert medical testimony necessity for IIED)
- Wecht v. PG Pub. Co., 725 A.2d 788 (Pa. Super. 1999) (stating Kazatsky bars IIED recovery absent medical confirmation)