Anderson v. Amco Ins. Co

In Anderson v. Amco Ins. Co., 541 N.W.2d 8 (Minn. App. 1995), the Minnesota Court of Appeals considered an insured's claim for no-fault coverage for psychological treatment of panic attacks that the insured claimed arose out of an automobile accident. The court said although the panic attacks produced some physical effects such as "spells during which she feels her heart is racing, her legs are weak, she feels vertiginous and occasionally nauseous, and occasionally her mouth feels dry," the insured did not seek treatment for those physical effects. Id. at 9 n.1. The court held Minnesota's statutory no-fault provisions did not mandate coverage for treatment of the panic attacks. Id. at 9-10. The court also rejected the insured's argument that the no-fault policy's definition of "bodily harm" should be construed to include "panic attacks," in part because the insured did not allege the panic attacks resulted in physical manifestations. Id. at 10-11.