Twin City Bank v. Isaacs
In Twin City Bank v. Isaacs, 283 Ark. 127, 672 S.W.2d 651 (Ark 1984), the Supreme Court of Arkansas recognized that "the type of mental anguish suffered under 4-402 does not need to rise to the higher standard of injury for intentional infliction of emotional distress." Isaacs, 672 S.W.2d at 654.
It further compared these intangible injuries to those types of damages recognized in defamation actions. Id.