In Vance v. Vance, 286 Md. 490, 496-97, 408 A.2d 728 (1979), Muriel Vance, the plaintiff, sought and obtained a decree awarding her alimony and child support after her husband of eighteen years, Dr. Arnold Vance, left her and their two children for another woman. Id. at 492. Dr. Vance immediately filed a motion to strike the decree and annul the marriage on the ground that it was void because Dr. Vance was not divorced from his first wife when he purported to marry Muriel. Although Dr. Vance had believed his divorce was final at the time he married Muriel, he learned nearly a month after the marriage that his divorce decree had become final several weeks after his purported marriage to Muriel. Id. Dr. Vance, however, never disclosed this fact to Muriel prior to filing his motion to strike. Thereafter, Muriel sued Dr. Vance, for, inter alia, compensatory damages for emotional distress that she claimed to have suffered as a result of Dr. Vance's negligent misrepresentation over their eighteen years of marriage, concerning his marital status at the time of their ostensible marriage. Id. at 492-93. The Vance Court noted several means by which the requisite "physical injury" resulting from emotional distress may be proved. The first few categories, according to the Court, "pertain to manifestations of a physical injury through evidence of an external condition or by symptoms of a pathological or physiological state." Id. at 500. Importantly, the Court stated that a physical injury can be proven "by evidence indicative of a mental state . . . . In the context of the Bowman rule, therefore, the term 'physical' is not used in its ordinary dictionary sense . . ., but is instead used to represent that the injury for which recovery is sought is capable of objective determination." Id. . Then, turning to the facts of the case, the Vance Court cited evidence that upon learning that her marriage was invalid Muriel (1) went into a state of shock, (2) engaged in spontaneous crying and seemed detached and unaware of her own presence, (3) was unable to function normally, sleep, or socialize, (4) experienced symptoms of an ulcer, and (5) suffered an emotional collapse and depression, which manifested itself through unkept hair, sunken cheeks, and dark eyes. Applying the "capable of objective determination" standard, the Court concluded that Muriel had suffered a compensable injury. Specifically, the court held that the evidence supported a jury finding that Dr. Vance's negligent misrepresentation had caused a "physical" injury to Muriel in the form of an objectively manifested nervous disorder that was sufficient to satisfy the "physical injury" requirement, as adopted in Bowman. Id. In Vance v. Vance, in the midst of divorce proceedings, the defendant told the plaintiff that they were not actually married because, when they had been "married" some 20 years prior, his divorce from his first wife was not finalized. He thought that it had been, but, upon learning about a month later that it had not, he did not inform the plaintiff. The plaintiff learned of this for the first time during the divorce proceedings. The plaintiff sued the defendant for negligent misrepresentation, seeking to recover damages for emotional distress. She alleged that, upon learning that her marriage had been a nullity and that her children were illegitimate (which she believed but actually was not the case), she had "suffered an emotional collapse and depression which manifested itself in her external condition," i.e., changes in her appearance, symptoms of an ulcer, inability to sleep, and inability to function normally. See id. at 501. The defendant took the position that because there was no physical impact, the plaintiff could not recover damages for emotional distress. Rejecting that argument, the Court of Appeals held that the plaintiff could recover damages for emotional distress that had manifested itself by physical symptoms and that was proximately caused by the defendant's negligently misrepresenting to the plaintiff that they had been legally married. In Vance, the plaintiff sustained no injury at all until she learned of the defendant's 20-year-old misrepresentation. Furthermore, the defendant's misrepresentation about the status of the parties' marriage was itself the wrongful act that caused the plaintiff's harm. The plaintiff's physical injury arose from the depression and anxiety that resulted from her discovery of the misrepresentation. The Court of Appeals upheld an award of damages for emotional distress in a negligent misrepresentation case. The defendant had falsely misrepresented to the plaintiff that he was divorced and therefore free to marry; and on that basis, the two had participated in a marriage ceremony and lived together as though married. The plaintiff later learned, in the course of divorce proceedings, that her "husband" had been married when they "married," so they were never married at all. At trial, the plaintiff presented evidence that, upon learning that she and the defendant were never married, she could not function, could not sleep, had difficulty communicating and socializing with other people, and spent "long periods of time crying and sobbing." Vance, supra, 286 Md. at 493-94. No medical evidence was presented to support the plaintiff's claim of emotional distress. The jury awarded the plaintiff $ 50,000 in damages. The trial court granted a JNOV, on the ground that the plaintiff had not offered evidence of a physical injury sufficient to support an award of damages for emotional distress in a negligence case. On review, the Court of Appeals held that the evidence was sufficient to support the award of damages for emotional distress. The Court discussed the history of what is known as the "physical injury rule," beginning with Green v. Shoemaker, 111 Md. 69, 73 A. 688 (1909). That case held that it was not necessary for a plaintiff in a negligence action to prove a physical impact, in order to recover damages for emotional distress; rather, it was sufficient for the plaintiff to show that the negligence had caused him some "physical injury." Later, in Bowman v. Williams, 164 Md. 397, 165 A. 182 (1933), the "physical injury rule" was clarified to mean that a plaintiff can recover damages for emotional distress in a negligence action, in the absence of a physical impact, when the emotional distress has "resulted in some clearly apparent and substantial physical injury, as manifested by an external condition or by symptoms clearly indicated of a resultant pathological, physiological, or mental state." Vance, supra, 286 Md. at 500 (quoting Bowman, supra, 164 Md. at 404). The Court in Vance explained that the underlying purpose of the "physical injury rule" is to "require objective evidence to guard against feigned claims." 286 Md. at 500.