A review of Ohio cases reveals that Ohio law declares there cannot be recovery for mental distress unless it is accompanied by contemporaneous physical injury (i.e., contact), or unless the act was wilful, wanton or intentional. No Ohio cases were found where recovery for purely mental suffering, caused negligently, in and of itself was permitted.
James G. Young, Damages for Emotional Distress in Ohio, 15 Clev.-Marshall L. Rev. 51 (1966)
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