The early decisions involving negligently inflicted emotional distress and resulting physical injuries generally held that a contemporaneous physical impact was a prerequisite to a right of recovery. This requirement, commonly referred to as the "impact rule," has today been rejected or abrogated in most American jurisdictions. The status of this rule in Virginia has been unclear since the decision of Bowles v. May because of conflicting interpretations
Tort Law- Emotional Disturbances and Resulting Physical Injuries Occasioned By Negligence,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol8/iss2/21