On the surface, Derousse v. State Farm Mutual Automobile Insurance. Co. may be a relatively minor matter of statutory interpretation: Does Missouri insurance law require coverage for pure emotional distress caused by uninsured motorists? In answering the question, however, the court's generous rules of interpretation signal its recent willingness to expand recovery for emotional distress claims. Traditionally, Missouri took a conservative approach to allowing emotional damages in tort claims. Derousse is a stark example that the old regime is a relic.
Joseph N. Blumberg,
Pleading Panic: Pure Emotional Damages as Sickness or Disease for Bodily Injury Claims,
76 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol76/iss3/11