Nationwide Mut. Fire Ins. Co. v. Lam

In Nationwide Mut. Fire Ins. Co. v. Lam, 248 Ga. App. 134, 136-137 (2) (546 SE2d 283) (2001), the plaintiff sought to recover for emotional distress that she claimed stemmed from a collision in which her and her husband's automobile was wrecked. In addition to presenting medical bills as evidence of her pecuniary loss, the Lam plaintiff pointed to her wrecked vehicle as evidence that her "personal property was damaged in the collision." Id. at 138. Our holding that she could pursue her claim for emotional distress was thus based in part upon the plaintiff's showing that she had sustained a pecuniary loss resulting from a trespass, which we recognized as "an unlawful interference with one's person, property, or rights." Id. at 138 (2), n. 5