In Sprague v. Equifax, Inc. (1985) 166 Cal.App.3d 1012, the plaintiff sued the defendant for fraudulently terminating disability payments. In that case, the plaintiff purchased a credit disability policy to cover payments on a $ 21,687 loan in case he became disabled. Shortly thereafter the plaintiff injured his back while loading a clothes dryer onto a truck. After paying benefits for 18 months, the carrier stopped making payments. Two months later an adjusting company for the carrier advised the plaintiff that the benefits had been terminated in error and payments began anew. Defendant Equifax, a company involved in investigating insurance claims on behalf of insurance companies, was then contacted to set up a medical exam for the plaintiff. At the request of Equifax, the plaintiff was sent to a physician for an exam. Equifax did not send medical records to the doctor and provided the doctor with an erroneous definition of "total disability" under the terms of the policy. Following the exam, the plaintiff was deemed not totally disabled and benefits were again discontinued. Ten months later, benefits were reinstated. The issue before the court was whether the plaintiff was entitled to damages for emotional distress after benefits were reinstated for the last time. In explaining the need for economic injury as an underpinning for the recovery of emotional distress damages on a fraud claim, the court stated: "Damages for mental distress have . . . been awarded in cases where the tortious conduct was an interference with property rights without any personal injuries apart from the mental distress. . . . The principal reason for limiting recovery of damages for mental distress is that to permit recovery of such damages would open the door to fictitious claims, to recovery for mere bad manners . . . . Obviously, where, as here, the claim is actionable and has resulted in substantial damages apart from those due to mental distress, the danger of fictitious claims is reduced, and we are not here concerned with mere bad manners or trivialities but tortious conduct resulting in substantial invasions of clearly protected interests." (Id. at p. 1030.) "An award of damages for emotional distress resulting from tortious termination of disability benefits is not limited as a matter of law to the time during which the economic harm continues totally unabated. Those cases which have allowed emotional distress as an element of damages resulting from tortious breach of insurance contracts have required economic harm only to ensure, as a threshold matter, that an actual wrong has been committed against plaintiff." (Ibid.)