Adams v. Uno Rests., Inc – Case Brief Summary (Rhode Island)

In Adams v. Uno Rests., Inc., 794 A.2d 489, 492 (R.I. 2002), the court bypassed the expert testimony requirement because plaintiff's complaint to the police, arrest, criminal charge for disorderly conduct, arraignment, revocation of his military security clearance, and disqualification from an overseas mission provided "objective and uncontradicted evidence," from which "an ordinary lay person or trial juror would be capable of determining without the aid of expert medical testimony whether emotional distress and humiliation could ordinarily and naturally follow from such events." Adams, 794 A.2d at 493.

The court distinguished the plaintiff's case from "the usual case where a claim for emotional distress and humiliation is oftentimes made without objective facts to substantiate such a claim." Id.