Does the tort of outrage allow for mental anguish to be recoverable in a wrongful death action?

MultiRegion, United States of America

The following excerpt is from Pike v. U.S., 652 F.2d 31 (9th Cir. 1981):

Wash.Rev.Code 4.20.020. Pike relies largely on the dissent in Grimsby v. Samson, 85 Wash.2d 52, 63, 530 P.2d 291, 297 (1975) (en banc). The dissent opposed recognition of the tort of outrage permitting recovery for mental anguish caused by the death of the plaintiff's wife on the theory that double recovery would result. The dissent stated that damages for mental anguish were also recoverable in a wrongful death action.

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