Washington Law Review


J. R. R.


Plaintiff hired fifteen-year-old Reed Christensen to care for her five-year-old daughter upon the representation of his parents that he was a good and capable baby-sitter. The parents knew but did not disclose that their son had a lengthy history of sexually assaulting young girls. In the span of five months the baby-sitter molested the plaintiff's daughter between two and five times. Upon learning of the assaults, plaintiff suffered severe emotional distress requiring treatment by a physician, hospitalization, and psychiatric care. The plaintiffs claim against the defendant parents and their son alleged mental anguish proximately caused her by the knowledge of sexual assaults on her daughter. On motion for summary judgment, this claim was dismissed as to the defendant parents. Held: As a matter of law there can be no recovery for negligent inffiction of emotional harm absent reasonable fear of or actual physical trauma. Schurk v. Christensen, 80 Wn. 2d 652, 497 P.2d 937 (1972).

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